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Records Management Program Components
144 (November 1991 draft) Model Regional Records Management Manual
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Information Security
INFORMATION SECURITY
EPA's information security program has established formal
policy and guidance that recognizes that information is an Agency asset
and that EPA is highly dependent on its information resources to carry
out its mission. Under these policy statements and manuals,
information resources are defined as automated information systems,
computerized data bases, computer programs, collections of paper
records, information on microfiche or microfilm, and computer
installations.
In determining responsibilities for information security, EPA
policy relies on a framework of three primary roles: information
owner, user, and custodian. The owner of the information is the
individual or organization who creates and sponsors it. Ownership
involves authority and responsibility for the information, either in a
programmatic or administrative sense. The owner determines the
sensitivity of the records and decides who will be allowed to use them.
The users are individuals who are authorized by the owner to access an
application or a collection of information. Cu&todians possess ADP
equipment or the files housing paper records. The custodian is the
individual(s) responsible for the records in the property management
sense.
Regional records officers, as the custodians of the regions'
records, are responsible for establishing procedures for securing the
information resources.
Objective
The objectives of a regional records security program are
to maintain the availability of general management and
program records while protecting their confidentiality and
ensuring their integrity by safeguarding them from loss,
alteration, or damage.
Legal /Administrative Requirements
The listing on the following page highlights the major
legal and administrative requirements for records security with
which the regional offices must comolv.
A^r t_ bk* V»* »^» fc*X* ** ***.*»v^fc» fc» V* V *.. • W^>| ***» W**»W*»fc^ J
which the regional offices must comply.
Model Regional Records Management Manual (November 1991 draft) 145
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Records Management Program Components
LEGAt AND ADMINISTRATIVE REQUIREMENTS
FOR RECORDS SECURITY
EPA Information Security Manual
Electronic Records Management:
Final Rule
Executive Order 12656:Assignment
of Emergency Preparedness
Responsibilities
EPA security policy and
procedures contained in this
document must be addressed
Strict procedures for
restricting access, as well as
preparing backup and recovery
mechanisms for electronic
records are required
Lead and support
responsibilities for protecting
EPA records in time of
emergency must be assigned
For more detailed information on the requirements identified in
each citation, the appropriate document should be consulted.
Approaches
Key issues in' implementing the policies of EPA's
information security program are:
• Identifying and outlining responsibilities of those
records management professionals charged with
protecting records security
• Determining the sensitivity of the records holdings
• Identifying the primary threats to records
management information systems
• Developing procedures to address each of these
threats, balancing the need for integrity against the
requirements for access and confidentiality
• Communicating established procedures to all
owners and users of records.
146
(November 1991 draft)
Model Regional Records Management Manual
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Information Security
Managerial and administrative roles - Because
information security covers a variety of information
resources and involves many different employees and
supervisors, it is important to have one management
official in each program and administrative division
coordinate the security for that division. The regional
records management programs should identify a records
management liaison in each program who should assume
records security as part of his/her responsibilities. In
addition, the Regional Records Management Coordinator
has overall responsibility for maintaining the records
(including related ADP equipment) entrusted to the
records center or centers. Therefore, the Regional Records
Management Coordinator is charged with enforcing
records management procedures that are designed to
protect records from loss or damage and protect the
confidentiality of sensitive records. See following page.
Electronic records have a unique set of
requirements for security, and regions should designate a
person(s) to be responsible for security at the region's
computer processing installations (e.g., LAN admin-
istrator; mini-/mainframe administrator). They approach
information security both from an installation or
equipment perspective and from an application (or
system) perspective.
Determining records sensitivity - Over the years,
EPA has developed several sets of procedures governing
specific types of sensitive information. The great majority
of these existing procedures deal with some type of
confidential information, especially confidential business
information (CBI). These procedures are typically issued
by EPA organizations with statutory authority for the
information (for example, the Office of Pesticides and
Toxic Substances for TSCA or FIFRA CBI). Owners of
regional records may refer to the documents listed in the
References section of this chapter to review existing
organizational standards and procedures for sensitive
information that must be adhered to.
Model Regional Records Management Manual (November 1991 draft) 147
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Records Management Program Components
INFORMATION SECURITY: RESPONSIBILITIES BY ROLE
ROLE
IRM Branch Chief
RESPONSIBILITIES
Implements the organization-wide
security program. Designates a
responsible person at each division.
Division Director (Record owner) Determines information
sensitivity. Assigns custody.
Authorizes users. Specifies backup
and availability requirements.
Makes sure users and custodian
adhere to security requirements.
Regional Records Management
Coordinator
Records Officers
Specifics and approves security
controls. Establishes general
security procedures in consultation
with the records officers.
Enforces written security procedures
in daily operations. Trains records
center staff on security policy and
procedures.
The Sensitivity Evaluation Table on the following
page is from EPA's Information Security Manual and may
be used as a worksheet for evaluating sensitivity of a
particular record. Following completion of this step, the
owner may wish to consult with his/her records officers
or the Regional Records Management Coordinator to
determine the relevant security objective (availability/
integrity/confidentiality) and sensitivity level (high or
medium) based on the type of information the collection
contains. Senior regional managers may choose to review
the sensitivity designations assigned to significant records
collections, as the implementation of security safeguards
for these records can involve considerable expense and
investment of staff time.
Threats to records security - Records are vulnerable
to threats to each of the three security objectives. Threats
to the availability of records include theft, accidental
destruction (e.g., flood, fire or human error) or deliberate
destruction by vandals or a disgruntled employee.
148
(November 1991 draft)
Model Regional Records Management Manual
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Information Security
Sensitivity Evaluation Table
EPA Information Security Manual, 1989
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Model Regional Records Management Manual
(November 1991 draft)
149
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Records Management Program Components
Threats to integrity include accidental distortion
(particularly with electronic records) or deliberate
distortion for the purpose of revenge or to perpetrate or
cover up fraudulent activity.
Confidentiality of records may be threatened
through unauthorized disclosure of stored documents
(breakdown of security in the records center or deliberate
unauthorized sharing), or carelessness in handling or
creating sensitive documents (printer or copier waste
paper not destroyed or disk copies of electronic records not
protected). Procedures should be implemented by the
regions to address each of these threats.
Procedures for maintaining records security - In
order to maintain the availability of regional records, the
records officers should store the records (paper,
microform, electronic or magnetic disk) in appropriate
storage equipment, away from potential heat or water
damage. Sensitive records should be stored in a fireproof
file cabinet and those in off-site storage should be
available within hours. A document control and tracking
system must be established for the records center to
facilitate retrieval and prevent loss. In addition, a
procedure must be established to enforce the access control
list (persons allowed access to the collection) established by
the owner of the records. (See Section III.3 on Document
Control in this manual).
Procedures to ensure integrity must balance the
needs of availability against those of confidentiality.
Integrity involves elements of the availability objective
because if information is altered or partially destroyed, an
intact backup copy must be made available. On the other
hand, integrity involves elements of the confidentiality
objective because preventing fraud and sabotage are
largely problems of controlling access. Protecting the
integrity of the records involves adhering to all the
security procedures established to control availability, and,
in addition, keeping sensitive records in a locked cabinet
or room whenever the records are not in use. Locks
should be changed periodically or whenever there is a
change in authorized users.
150 (November 1991 draft) Model Regional Records Management Manual
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Information Security
Preserving confidentiality involves controlling
access to records. Access controls for regional records are
generally of two types: physical, such as door locks, and
administrative, such as lists that specify who may have
access to the records. Strict policies on photocopying of
records should be established; photocopying by anyone
other than the owner of the records is generally
prohibited. All confidential paper documents must be
shredded or burned before being thrown away. Discarded
microform should be placed in burn bags for proper
disposal. Magnetic disks should be properly erased and
overwritten before being used again or disposed of.
The EPA Information Security Manual may provide
additional guidance for developing an information
security program.
Communicating security measures to owners and
users - It is important to the success of the Regional
security program that the owners, users and custodians of
the records know and understand the security measures
in place. The regional records managers may assume
responsibility for presenting training sessions and/or
distributing written material to staff at all levels on both
basic information security and region-specific procedures
(See Section III.9, Staff Communication, in this manual).
References
Guidance to assist in the design of a records security
program can be found in several.existing documents, including:
• EPA Information Security Manual
• EPA Information Security Manual for Personal
Computers
• OPTS TSCA CBI Security Manual
• OPTS FIFRA CBI Security Manual
• OARM National Security Information Handbook
• OSWER RCRA CBI Procedures
Model Regional Records Management Manual (November 1991 draft) 151
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Records Management Program Components
OECM Enforcement Docket security procedures
OAR, OMS Procedures for Handling Auto
Manufacturers' Proprietary Data
AOR, OAQPS CBI procedures
Office of the Inspector General Manual
OW procedures for trade secret data
Executive Order 12656 on Assignment of
Emergency Preparedness Responsibilities.
152 (November 1991 draft) Model Regional Records Management Manual
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Public Access
7. ACCOMMODATING PUBLIC ACCESS
REQUIREMENTS
The foundation for public access within EPA is the belief that an
informed public is essential to meeting the Agency's mission to protect
human health and the environment and to establish and enforce
environmental regulations. Therefore, the objective of public access in
a global context is to make EPA's information available to the public in
an cost effective, appropriate format, while meeting all applicable
federal and EPA standards.
Regional managers should view the records 'management
program as a critical component of EPA's overall public access effort.
For example, legislation increasingly requires, and members of the
public increasingly demand, direct access to many records maintained
at the regional level, such as the Superfund Administrative Record,
National Contingency Plan, and other records contained in various
media program or administrative dockets. Additionally, regional
libraries and records centers are supporting growing numbers of
responses to Freedom of Information Act (FOIA) requests, even though
the primary responsibility for responding to the FOLAs may rest with
the Office of Public Affairs (or the Information Management Branch)
and the relevant program or administrative offices. Therefore, public
access issues and how to address them are important factors to be
considered by the regional records management programs.
Objective
The public access objective of the regional records
management program is to facilitate efficient EPA responses to
requests from the public to review or obtain information.
.Legal/'Administrative Requirements
The listing on the following page highlights the major
legal and administrative requirements for public access with
which the regional offices must comply.
Model Regional Records Management Manual (November 1991 draft) 153
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Records Management Program Components
LEGACANCTADMINISTRATIVE REQUIREMENT
Wl* GOVERNING PUBLIC ACCESS
Freedom of Information Act (5
U.S.C. 552)
EPA Freedom of Information Act
Manual, 1986
Administrative Procedures Act
of 1966
Electronic Records Management:
Final Rule, 1990
Comprehensive Environmental
Response, Compensation, and
Liability Act
Final Guidance on Administrative
Records for Selection of CERCLA
Response Actions (OSWER Directive
#9833.3A-1)
EPA Contracting Policies (April
1990 Memorandum from The
Administrator)
Requires Federal agencies to make
records available to the public unless
they meet one of nine exemptions
Outlines procedures for handling
FOIAs within EPA
Requires Federal agencies to make all
substantive rules and statements of
general policy available and to give
notice of proposed rulemaking so that
interested persons can participate
Requires controls over classified.
proprietary, and Privacy Act
information stored electronically
Requires EPA to make administrative
records and proposed National
Contingency Plan records available to
the public
Outlines procedures for public access
to removal and remedial response
actions, including those open to public
inspection at a site
Prohibits the actual preparation of
FOIA responses, other than routine,
non-judgmental correspondence by
contractors and lists support by
contractors in preparing FOIA
responses as an activity of potential
vulnerability
For more detailed information on the requirements identified in
each citation, the appropriate document should be consulted.
154
(November 1991 draft)
Model Regional Records Management Manual
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Public Access
Approaches
To meet the public access objective and the corresponding
legal and administrative requirements identified on the
previous page, Assistant Regional Administrators and regional
records managers must be concerned with achieving two basic
criteria:
• Meeting the needs of the public to review or obtain
information within the context of the provisions of
relevant legislation, such as CERCLA, FOIA, and
other administrative guidance.
• Improving EPA's efficiency in locating records
needed to respond to the public's requests for
information.
To meet these criteria, the regional records management
program should:
• Provide a public viewing room(s) to enable
members of the public to review records of interest
• Promote efficient access to records by organizing
and maintaining the records in an appropriate
manner.
Regional records centers will play a key role in the implementa-
tion of each of these approaches.
To facilitate access while protecting the integrity of EPA's
records, the public viewing area should have the following
characteristics. Specifically, the viewing area should:
• Be secure to ensure that members of the public are
not able to access inappropriate information (e.g.,
Confidential Business Information, enforcement
sensitive information, or other files to which they
have not been authorized access)
• Be accessible to the public without allowing access
to other secure areas within the EPA facility
Model Regional Records Management Manual (November 1991 draft) 155
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Records Management Program Components
• Have a sufficient and appropriately trained staff to
assist the public and EPA program staff with their
requests, locate the relevant records, and monitor
use of the records to protect integrity
• Use copies rather than originals where possible,
especially for frequently requested items
• Have sufficient space to allow the public to review
records
• Have available photocopying equipment or services
to allow the public, or program staff responding to
requests from the public, to make copies.
For records management programs that handle large
volumes of records and that receive extensive numbers of public
requests to view these records, the program may want to
consider making information that is not CBI or enforcement
sensitive available to the public in non-paper format, such as
microfilm, microfiche, or electronic. If microform is used,
requestors could use reader/printers to review the information
and to make copies of relevant documents. Use of microform
offers benefits to both EPA and the public as it facilitates access to
the information by the requestor while protecting the integrity of
the original records. If public access to electronic information,
such as a database, is allowed in the viewing room, precautions
need to be taken to ensure that members of the public cannot
access CBI, enforcement sensitive, or Privacy Act information
that is stored in the database or alter or otherwise abuse the
integrity of the electronic record.
Records management programs will also need to develop
operating procedures to support the public viewing room. These
procedures should cover topic-areas such as:
• Check in and check out
• Duplication
• Care of documents while in use by the public (i.e.,
instructions specifying that records should not be
written on or otherwise marked).
156 (November 1991 draft) Model Regional Records Management Manual
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Public Access
For assistance in this area, regional records officers should refer
to Section III.3, Document Control, of this document as well as to
the operating procedures of EPA libraries, the FRC and regional
archives. Examples of forms used in various regional offices are
included in the attachments at the end of this chapter.
The second approach to facilitating public requests to
information involves improving EPA's ability to locate and
retrieve records in which members of the public are interested.
This capability is particularly important with regard to
improving responses to FOIA requests. If the records are
organized and maintained so that specific documents can be
easily located, then this expedites preparation of the response.
Records management staff can further assist the program or
administrative staff by retrieving records for the staff member
and by making copies of specific records. The ability to easily
locate records also supports the functions of the public viewing
room.
Contractor Participation
Because most of the staff in the Regions involved with
organizing and maintaining records are currently contractors,
their involvement with FOIAs raises legal issues. As stated in
the legal and administrative requirements section, the
involvement of contractors in preparing responses to FOIAs is
prohibited in all but cases of routine correspondence, which does
not involve judgment. Any contractor support in drafting FOIA
responses is viewed as an activity of "potential vulnerability."
Due to these constraints, it is most acceptable for contractors to be
involved with FOIAs only in terms of facilitating the retrieval
and duplication of the required records for the program or
administrative staff completing the FOIAs.
Existing contracting policies do allow for some flexibility
in utilizing contractor support to respond to routine
correspondence requiring no judgment. For example, it may be
appropriate for a contractor to retrieve a specified document
requested through a FOIA, while a request for all information
relevant to contamination at a Superfund site should be handled
by the appropriate Remedial Program Manager (RPM) or On-
Scene Coordinator (OSC). However, once the RPM or OSC has
identified the document to be used in the response, contractors
can copy and assemble them. Allowing contractor staff to assist
Model Regional Records Management Manual (November 1991 draft) 157
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Records Management Program Components
with the preparation of responses for routine correspondence,
not involving judgment, may help reduce the burden on
program or administrative staff. The definition of this type of
FOLA would need to be standardized and reviewed by the Office
of Regional Counsel.
References
The following documents contain information on public
access that may be useful when considering how to
accommodate public access requirements into the Regional
records management program.
• EPA Freedom of Information Act Manual, 1986
• Final Guidance on Administrative Records for
Selecting CERCLA Response Actions, 1990 (OSWER
Directive 9833.3A-1)
• EPA's draft Public Access Policy (currently being
circulated for comment)
• Memorandum from William Reilly, "Contracting
at EPA," April 17,1990
153 (November 1991 draft) Model Regional Records Management Manual
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. Public Access
ATTACHMENTS
Region VII Visitor Log
Request Form for Public Dockets
Public Docket Problem Report Form
Model Regional Records Management Manual (November 1991 draft) 159
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Records Management Program Components
160 (November 1991 draft) Model Regional Records Management Manual
-------
Public Access
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Model Regional Records Management Manual
(November 1991 draft)
161
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Records Management Program Components
162 (November 1991 draft) Model Regional Records Management Manual
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Public Access
Request Form for Public Dockets
Instructions:
• Members of the public may request public docket records ooly. .
• Publk Ar*-*y inxrdi do not circulzte. They may only be used in tbe Records Outer Public Reading Room.
• Limited numbers of copies may be nude on the Records Center's copy machine.
- Please complete all appropriate sections of the form.
• Questions concerning (he use of public rtorlrit records may be directed to the Records Center Manager.
1. Type of Public Docket (circle one):
NPL Administrative Record Federal Facility Docket
2. Site Name:
NPL Docket
3. State (circle one): CT
MA
ME NH
RI
VT
4. Material to be
Viewed
Volume(s)
For Records Center Staff Use Only
Accession No.
c:
Given to
Requestor
Date & Time
Returned
by Requestor
.c
5. Name of Requestor
6. Representing:
7. Address:
8. Telephone Number
EPA Refioo I (4/I4/U)
Model Regional Records Management Manual
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163
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Records Management Program Components
164 (November 1991 draft) Model Regional Records Management Manual
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Public Access
Public Docket Problem Report
Instructions:
Have you experienced a problem wtuk asmf • poblk docket? Please provide as much information as pocsibte. This will
allow the Region to comet (he problem in a timely manner. If you have any qoabom. pkate consult w«h the Saperfuod
Records Center Manager.
1. Type of Public Docket (circle one):
Administrative Record Federal Facility Docket NPL Docket
Site/Facility Name:
2.
3.
4.
5. State (circle one): IA KS MO NE
CERCLISIDf (if known):
Operable Unit
Name of Person Reporting Problem:
Telephone*:
8. Date:
9. Type of Problem (select all that apply):
Type of Problem
Major/Minor
Break
Index
Citation No.
F] Document listed in the Public Docket Index is missing from
the Public Docket
Document located in the Public Docket is illegible (e.g.,
copy poorly reproduced).
Document located in the Public Docket is damaged (e.g., torn;
stained).
Document in the Public Docket missing page(s).
Page(s):
Public Docket citation appears to be incorrect Give correct
citation in Section 10.
Other
10: Additional Information on the Problem:
(For example: document citation)
For Supexfund Record* Center Staff Use Only
EPA Rejio. VH (WW)
Model Regional Records Management Manual
(November 1991 draft)
765
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Records Management Program Components
166 ' (November 1991 draft) Model Regional Records Management Manual
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Records Management Technology
8. ELECTRONIC RECORDS MANAGEMENT
TECHNOLOGY
Records management is one of the fundamental administrative
activities performed at EPA in support of ongoing mission-oriented
operations. All types of EPA employees, whether they are
administrative or knowledge workers4, are involved with records
management in some capacity. This involvement takes one of three
forms - owner, user, or custodian - as discussed earlier. As the primary
custodian of most of a region's records, the regional records
management program has a unique opportunity to promote improved
productivity of the region's records owners and users by facilitating
access to EPA's records. Many steps have already been taken in this
direction due to the creation of records centers in most regional offices.
However, the application of appropriate technologies to records
management activities is key to improving access to information and
thus continuing to enhance worker productivity. Additionally, the
evaluation and use of technological applications to improve records
management today will position regions to take full advantage of the
opportunities offered by technological advancements in the future.
This section will discuss technology in records management
through presenting the basic objective of utilizing technology in
records management, the legal and administrative requirements, the
regional records officer's role in evaluating and selecting technological
applications, and information on various technological applications
appropriate for use in the records management environment.
Additionally, a scenario is offered at the conclusion to this section to
provide one idea of how records management will be conducted in a
future office environment.
4 The "Technology Assessment and Technology Impact Reports" developed by
Booz* Allen & Hamilton Inc. for the Comprehensive Analysis of Records and Forms
Management Program in EPA Headquarters Offices Study define two types of
workers - administrative and knowledge. Administrative workers perform and
manage those ongoing activities necessary to support the operations of the
organization. The knowledge worker performs mission-related activities.
Model Regional Records Management Manual (November 1991 draft) 167
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Records Management Program Components
Objective
The objectives of technology in a records management
system are to increase accessibility, improve cost effectiveness,
and provide strict document control, in accordance with the
needs and regulations of the Agency.
Legal /Administrative Requirements
Specific legal and administrative requirements exist with
respect to the application of technology in records management.
A listing of these requirements is presented in the graphic on the
following page.
168 (November 1991 draft) Model Regional Records Management Manual
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Records Management Technology
LEGAL AND ADMINISTRATIVE REQUIREMENTS--—
FOR RECORDS MANAGEMENT TECHNOLOGY
General Federal Guidelines at 44 U. S. C.
3101-07. 41 CFR 101
NARA Regulations at 36 CFR Part 1234
NARA Regulations at 36 CFR Part 1230
NARA Bulletin 91:2: Use of Optical Disc
Systems to Store Permanent Federal
Records
NARA Regulations at 365 CFR 123.183
Privacy Act of 1974 at 5 U.S.C. S52a
Paperwork Reduction Act of 1980
Electronic Communications Privacy Act
(P.L 99-508)
National Security Decision Directive
(NSDD) 145. September 17. 1984
EPA's Records Management Manual
EPA Information Security Manual
(December 1989)
Implementation of Image Processing
Systems (OIRM Policy Directive)
Electronic records must follow NARA
and Agency guidelines for the
security and disposition of records,
including destruction and transfer to
a Federal Records Center
Regulations establish standards for
the use of micrographic technology
with federal records
Agency may not transfer records
stored on optical disc to NARA
Agency must conform to standards
when transferring machine readable
records to National Archives
Agency will acquire and operate
information technology in an
effective and economical manner
All records management functions,
including electronic recordkeeping,
should be consolidated in a single
agency official
Agency must provide safeguards for
access to electronically transmitted
information
Agency must meet minimum security
requirements for civilian Federal
agencies for maintaining sensitive
data on computer systems
Manual contains information on how
to justify the need for micrographics
systems within the Agency
Manual explains how to comply with
electronic security requirements
outlined in the 1987 Information
Security Policy
Policy establishes the principles for
the acquisition and use of image
processing systems
Model Regional Records Management Manual
(November 1991 draft)
169
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Records Management Program Components
Approaches
This section covers two main areas:
• A framework that records officers can utilize to
evaluate and select appropriate technologies for use
in records management
• A discussion of the capabilities, advantages, and
disadvantages of the currently available
technologies.
These are each discussed in turn.
Evaluation Framework
A critical first step in evaluating and selecting
technological applications for use in records management is an
assessment of the effectiveness of current records management
policies, procedures, operations, and personnel.5 If the current
records management program is outdated, ineffective, or
unresponsive to the region's needs, the application of
technology will not solve these problems. Therefore, the
regional records manager should lead an assessment of the
current records management environment before embarking
upon additional assessment of technological solutions. This
assessment can be conducted through use of the following
framework:
• Define Organizational Mission - The records officer
should first define the goals, objectives, and
functions of the organization that the records
management program supports in the context of
EPA's overall goals and priorities.
Accomplishment of this task will necessitate
evaluation of mission statements, relevant laws,
regulations, and administrative policies,
organizational goals, and human resources
management issues. This definition establishes a
framework for identifying document management
needs.
Much of the information contained in this section is paraphrased from the Guidance
for Developing Image Processing Systems in EPA, February 1991. This document
should be referenced for more detailed information.
170 (November 1991 draft) Model Regional Records Management Manual
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Records Management Technology
Describe Current Document Management System -
The records officer needs to evaluate the current
records management system so as to obtain an
overall description of the life cycle of documents
critical to the operations and performance of the
office. This evaluation requires identifying the set
of records needed to support the office's functions
and then differentiating these documents by how
they are created and how they are used. For
example, the records could be categorized as forms,
reference materials, working and official
documents, or archival materials. The next
component of this task is to develop an overall
description of the records management system,
including identification of strengths and
weaknesses.
Define Document Management Problems - The
records officer next needs to dearly define
document management problems so as to identify
the region's needs in this area and potential
technological solutions. These problems can be
either unmet records management needs or
deficiencies in the existing system relative to the
organizational mission. Additionally, the records
officer must consider the resulting implications for
the region of correcting these problems.
Identify Document Management Needs - The
previous two tasks provide the framework for
identifying the required capabilities of an improved
records management system. The new system
should preserve existing strengths, correct system
weaknesses, and eliminate deficiencies. The
regional records manager can utilize five criteria to
establish a basis for evaluating alternative
technologies relative to records management needs:
Document Access - Frequency, speed, single
user or multi-user, and other access
characteristics
Document Storage - Storage quantity,
duration, and mandate (e.g., how long must
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Records Management Program Components
documents legally be retained) as well as
requirements for active or inactive
documents
Document Distribution - Extent of internal
and external distribution and type of
distribution
Document Control - Security requirements,
document accountability, and security for
portions of documents or for data from
documents
Document Processing - Single or multiple
persons processing documents and internal
and external document processing.
• Identify Possible Solution Areas - In this step, the
records officer identifies technological solution
options that meet the previously defined
requirements. These potential solutions may
include:
Improved paper-based systems
Microform systems using microfilm or
microfiche
Image Processing Systems
Hybrid combinations composed of the above
categories and other Management
Information Systems technologies.
After this mission-needs assessment has been completed,
the records officer should conduct a feasibility study to
determine if the proposed solution can be justified within the
context of existing constraints. Completion of this type of study
requires development of an operational cost baseline of the
existing system so that it can be compared to proposed solutions,
further refinement of the alternatives, development of cost
estimates for the alternatives, and consideration of other factors,
such as technological and organizational issues and additional
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mission needs unmet by the current records management
approach.6
Available Technologies
The following text provides an overview of available
technological applications through presenting descriptions,
advantages, and disadvantages of various technological
solutions which should be considered for use in records
management.
• Paper - Paper is currently the most common form
of information storage and has established the
standard for convenience, cost, and functionality
with regard to information transfer. The physical
characteristics of paper include a diverse range of
sizes, colors, thicknesses, and compositions. These
physical characteristics can convey a message
beyond that communicated by the actual
information which is stored. The expected lifetime
of paper depends upon the type used and the
environmental conditions in which it is stored; this
lifetime can range from a few days to hundreds of
years. Paper storage techniques are based upon the
physical filing of document and involve a trade-off
between file integrity and access (i.e., tightly
controlled documents must have restricted access
and thus are usually stored in a centralized location
whereas documents requiring significant access are
often copied and stored in decentralized locations).
Several techniques have been developed to
improve the effectiveness of storage and retrieval
and to reduce paper storage volumes.
Movable filing systems using mechanical
and electrical features to reduce the amount
of access space required between filing
cabinets and shelves. These types, of filing
systems allow documents to be stored at
much higher storage densities than standard
paper-based systems.
^ One approach to completing a feasibility study is discussed in detail in Chapter III
of the Guidance for Developing Image Processing Systems in EPA.
Model Regional Records Management Manual (November 1991 draft) 173
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Records Management Program Components
Computer-based indexing systems that
identify the storage location and control the
distribution of paper documents. The
location and description of each document
• can be entered into the system along with
tracking information.
Regardless of how the documents are stored, once
the volume exceeds available space, obsolete or
seldom-needed documents must be retired to a
remote location or destroyed. The following
graphic summarizes the advantages and
disadvantages of paper.
Advantages
Standard media for
information transfer
Admissible as legal
evidence
Any display format
and size is possible
Easy to reproduce
information
Easy to update
information
Easy to manually
browse documents
Disadvantages
Large storage space
required
Retrieval time may be
slow
Large volumes can be
difficult to manage and
expensive to move
Easy to loso or damage
documents
Changes may be difficult
to identify and track
Limitted to a single
arrangement scheme which
may or may not meet research
needs.
Micrographics - Micrographics involves a
photographic process in which the image of a
document is transferred by camera onto unexposed
film. The film is then subsequently exposed,
developed chemically or by heat, and stored in one
of the following forms:
Microfilm Rolls - Documents are
sequentially photographed on a film roll
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either 100 or 215 feet long using either 16
mm or 35 mm film. A 100 foot roll of 16 mm
film contains approximately 2,400 images of 8
1/2" X 11" pages. These rolls are stored in
open reels or enclosed cartridges.
Microfiche - Microfiche stores photographic
images of documents in a grid format on a
small rectangular piece of film. Each
microfiche has dimensions of 4" X 6" and
usually contains up to 98 images which can
be stored at a density of approximately 120
sheets per inch.
Jacketed Microfilm - Jacketed microfilm
combines microfilm roll and microfiche
storage techniques. After cutting standard
roll film to the appropriate length (based on
the width of the jacket), it is then inserted
into clear plastic jackets containing channels
for film. The images are initially developed
on microfilm rolls and then stored in rows
similar to microfiche. This format is easily
updated by adding or removing slides.
*»
Aperture Cards - Aperture cards use a
standard computer punch card to store a
piece of 35 mm film. The film is mounted in
a window, and information is then encoded
on the card so that the image can be sorted
and retrieved. Usually one image is stored
per card although multiple images can be
stored. These cards are frequently used for
engineering applications, including
architectural drawings, geographical maps,
and charts. Due to the outdated punch card
technology, aperture card applications are
currently being replaced with microfiche-
sized aperture cards that allow combined
storage of large format 35 mm images and
normal-sized document images.
The storage density of micrographics is usually
quite high, but special filming, processing, reading,
and printing equipment are required. Although
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Records Management Program Components
the filming and processing operations can be
performed by a service bureau, viewing and
printing equipment will need to be purchased. The
optical viewing equipment is available with
various capabilities, including differing
magnifications, screen sizes, and image retrieval
abilities. Micrographics printers allow a user to
produce a paper copy of the image on demand.
Additionally, various micrographic systems exist
that combine micrographies' high storage densities
with the capabilities of a computer. These systems,
which are discussed below, offer substantial
improvements for storing and accessing
documents.
Computer-Aided Retrieval (CAR) - CAR
systems are most useful for storing archived
documents that require infrequent retrieval.
Documents are photographed on microfilm
and descriptive information is entered for
each document in a computer data base. A
frame number or an image mark is encoded
next to each image on the film. The database
retains this number or mark and associates it
with the document description. To retrieve a
document, the descriptive information is
entered and the computer directs the image
reader to manipulate the film and retrieve
the image associated with the document.
Microfilm supported by CAR systems can be
used to transition to an optical disk system as
film based images can be scanned, converted
to a digital format, and transmitted to an
optical disk system. The film index is
accessed through the image processing
system.
s
Computer Output to Microfilm (COM) -
COM systems print computer-generated data
and scanned images directly onto film, thus
bypassing the need to produce a paper copy of
the data. This system is especially
appropriate when large amounts of
computer data or images stored on magnetic
or optical media" need to be permanently
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archived. The storage space on the magnetic
media can be reused.
Digitized Microfilm - These systems,
sometimes referred to as automated
document storage and retrieval systems
(ADSTAR) or videomicrographics systems,
convert document images stored on film to
digital data and then process them by
computer. Film rolls are automatically
retrieved and the selected images are located.
The image is then converted, via a scanner,
to a digital format where a computer
electronically processes and sends the
document to another computer or a printer.
The following graphic summarizes the basic
advantages and disadvantages of micrographics.
Advantages
High storage capacity
Admissible as legal
evidence
Well proven and tested
technology
Easy and cost effective
to duplicate
Most document formats
can be displayed
Low conversion costs
Disadvantages
Retrieval time may be slow
Film may be difficult
and expensive to update
Film can be easily lost
or damaged
Document browsing may
be time consuming
Image Processing Systems - Image processing
systems convert images to a digital format that can
be manipulated by a computer. When an image is
recorded using digital processes, it is scanned and
transformed into binary digits - ones and zeroes.
The digital format is then viewed on a computer
Model Regional Records Management Manual
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Records Management Program Components
terminal, printed, stored, or transmitted to other
users. However, electronic digitized images only
record a limited degree of detail. Virtually any
media that can store digital information can be used
to store digitized images, including the following:
Magnetic Storage - With magnetic storage
media, the digital values that comprise text
and image information are recorded as a
sequence of electrical charges on a
magnetically-coated surface, such as magnetic
tape, disks, and cards. There are wide
variations in data storage capacities and
access speeds of magnetic media.
•• Magnetic Tape - Information stored on
magnetic tape must be accessed
sequentially resulting in slow access
time. Storage capacities for magnetic
tape range from 5 to 10 megabytes of
data on a 100 foot length of tape. This
media is best suited for systems with a
large volume of transaction processing
(due to the high storage capacity and
low cost) and little to no need for
random data access.
•• Magnetic Disks - Information stored
on magnetic disks can be retrieved
quickly (usually within a fraction of a
second) due to the high speed,
continuous rotation of the disks.
However, in comparison to magnetic
tape, the storage capacity is limited.
Magnetic disks can be either hard disks
with high storage capacities or floppy
disks which are portable storage
media. Storage capacity for floppy
disks ranges from 720 to over 1,400
kilobytes of data. Hard disks for
personal computers hold from 20 to
over 200 megabytes while hard disks
for mini and mainframe computers
range from 500 megabytes to over 2
gigabytes of data per disk.
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Optical Storage - Optical storage media
contain digital values that compose text and
image information recorded by a laser light
as a series of holes or bubbles on a reflective
disk surface. The disk can be read by
reflecting laser light from the recorded
information through a detector back into a
computer. Optical storage devices come in
various forms.
•• Compact Disk/Read Only Memory
(CD/ROM) - CD/ROMs contain
prerecorded text or image information
that can only be read, not altered.
After a CD/ROM has been stamped
with information from the master
disk, no information can be changed
or added. This type of optical storage is
commonly used as a publishing
medium.
•• Write Once Read Many (WORM) -
WORM disks allow the user to record
information one time and then
subsequently read this information
repeatedly. These disks hold from 1 to
6 gigabytes of data per disk. WORM
disks provide a secure storage medium
that cannot be altered, thus making
these disks useful for long-term
storage or for highly sensitive
documents.
• • Erasable Optical Disk - Information can
be repeatedly written to and erased
from this storage medium. Erasable
optical disks generally store from 1 to 4
gigabytes of data/disk. These disks are
very useful when storage
requirements are high, and
information must be repeatedly
updated.
Model Regional Records Management Manual (November 1991 draft) 179
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Records Management Program Components
Image processing systems can be assembled so that
they perform one of three types of functions.
Retrieval Systems—Documents"
are scanned and stored on an optical disk
(WORM or erasable) and then displayed on a
monitor, reprinted, transmitted to another
location, or copied to another disk. After
scanning, paper documents are either stored
locally, archived at a remote location, or
destroyed. Storage and retrieval systems
offer many benefits:
•• Documents can be stored at a higher
density
• • Documents can be securely stored
•• Documents can be retrieved rapidly
• • Documents can be filed using a cross-
indexing method
• • Documents are always available for
use
While these benefits can lead to increased
productivity and efficiency, they must be
weighed against higher equipment and
startup costs and the as of yet unresolved
issue of legal admissibility for optical media.
Long Term Storage Systems - These systems
are used primarily for the long term storage
of documents requiring infrequent access.
Documents are scanned on optical media
(WORM or erasable) at a very high storage
capacity as the primary objective is to
maximize storage density with limited
consideration of access and retrieval time.
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Document Processing Systems - Document
processing systems allow information to be
added, validated, or extracted from a
document as it passes through the various
stages of processing. Instead of manually
processing a paper document, an electronic
form of the document is automatically
passed from one station to the next. This
capability simplifies and accelerates
document processing activities, such as
review and approval cycles. Document
processing offers many of the same
advantages as those listed for storage and
retrieval systems as well as offering
additional benefits resulting from the
networking capabilities. These benefits
include: electronic document transmission,
distribution, pacing, sequencing, prioritizing,
tracking of comments, and integration with
other systems. Software development and
maintenance costs are usually higher for
these systems than for storage and retrieval
systems. Those processes which are highly
procedural, time sensitive, or have
mandatory processing cycles are most
appropriate for this type of system. The
following graphic summarizes the
advantages and disadvantages of image
processing systems.
Model Regional Records Management Manual (November 1991 draft) 181
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Records Management Program Components
Advantages
High storage capacity
Rapid access to
documents
Easy to reproduce
information onto paper
Difficult to misplace or
damage documents
Document security and
integrity is enhanced
Single documents can be
simultaneously viewed
System can be easily
expanded
System can be integrated
with other
technologies/systems
Disadvantages
High equipment costs
High document conversion
time and costs
Environmentally-controlled
room may be required
High maintenance and
support costs
Inability to access documents
during system downtime
No decision on legal
admissibility
Hybrid Image Processing Systems - Hybrid image
processing systems employ many different
technologies to maximize performance, efficiency,
and cost effectiveness. A hybrid solution may
incorporate multiple storage techniques, such as
paper-based, micrographics, and imaging, as well as
other complementary information technologies,
such as bar coding, text processing, optical character
recognition (OCR), electronic data interchange
(EDI), electronic forms, network architectures,
facsimile transmission, and electronic and voice
mail. Hybrid systems may be appropriate where the
requirements are large, diverse, and complex.
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Office of the Future Scenario
In the future office environment, each employee will have a single
workstation at his/her desk connected to other workstations via local area
networks as well as to the national network as needed.7 The workstation will
be integrated with the voice communication system to provide enhanced
integration between data, voice, and image. However, due to cost constraints
and limited requirements to perform certain functions, not all workstations will
have all capabilities. Instead, strategically located areas will provide
specialized technology capabilities.
In a future office environment, such as this, records management will
operate in a different manner lhan it is currently. The following scenarios
provide examples of how the records management function might be completed
in this future office environment.
An EPA employee in a program office wants to determine the status of
his/her outstanding travel vouchers. The employee queries the computer and
learns that the previously submitted voucher has not been approved due to
inconsistencies between the information recorded on the form and the receipts
attached. As this employee does not have access to image at his/her desk,
he/she calls the Finance Office to resolve the problem. The employee in the
Finance Office retrieves the voucher in one window and the image of a scanned
dinner receipt in another. By comparing the two, the Finance employee is able
to discover, communicate, and, based upon the oflier employee's input, correct
the discrepancy.
The program office employee is then working on responding to a
Freedom of Information Act (FOIA) request which has been electronically
routed to him/her through the controlled correspondence system. In order to
respond to this FOIA, the employee needs to locate and examine relevant public
comments received in reference to a specific regulation. The employee calls up
an index to all the public comments and other information maintained in the
records center, electronically searches for the appropriate comments, and upon
locating the relevant comments, notes their location (i.e., appropriate records
center). As the comments of interest are listed as being available through
another program office's records center, the employee walks to the center and
utilizes its workstation to pull up the image of the comments in which he/she
is interested. The employee prints a copy of the image and returns to his/her
office to complete the FOIA response.
The information contained in this section is based upon the scenarios presented in
The "Technology Assessment and Technology Impact Reports" developed by
Booz* Allen & Hamilton Inc. for the Comprehensive Analysis of Records and Forms
Management Program in EPA Headquarters Offices Study.
Model Regional Records Management Manual
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Staff Communication
9. REGIONAL STAFF COMMUNICATION
In order to contribute to the operation of the records
management program, regional staff must first understand the
objectives, legal/administrative requirements, and functions of the
regional records management program. As creators and users of
regional records, program and general management staff contribute to
the regional records management program throughout the life cycle of
the record. These staff:
• Create records to be inventoried and managed by the
regional records management program
• Maintain records and provide insight to records
management staff regarding user needs, such as access
• Help determine how to manage inactive records through
disposition or storage.
The Regional Records Management Coordinator must take the lead in
communicating regional records management policies to ensure that
staff activities are conducted in a manner that is consistent with
national and regional records management program objectives. Two-
way communications between records management program staff and
program and general management personnel will lead to a broader
understanding of the Agency's role and responsibilities as custodian of
public information.
Objective
The overall objective for providing records management
information and resources to regional staff is to utilize
teamwork and information sharing to attain national and
regional records management program objectives.
In order to attain the goal of acting as a resource in records
management policies and procedures, the regional program
must be active in communicating records management
principles, accessible in assisting staff in integrating these
principles, and understanding of staff needs.
Model Regional Records Management Manual (November 1991 draft) 185
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Records Management Program Components
Legal/Administrative Requirements
The list below highlights the major legal/administrative
requirements for regional communications regarding the records
management program.
LEGAL AND ADMINISTRATIVE REQUIREMENTS
FOR REGIONAL STAFF COMMUNICATION
IRM Strategic Plan
1991-1995
Establishes IRM program commitments to:
• Increase end user knowledge through teamwork
and information sharing
- Ensure effective and appropriate handling of
Agency records through realistic guidelines for
records management
- Provide technical assistance and client support to
facilitate efficient use of IRM resources
Approach
The design of the region's records management
communication strategy should consider:
• Information needs of records users
• Selection of appropriate communication vehicles
• Frequency of regional communications.
Consideration of these variables will help the regional records
management program expand communication, leading to
increased mangement efficiency and productivity for regional
staff.
Information needs of records users - Under the leadership
of the Regional Records Management Coordinator, the regional
records officers should take the lead in designing
communications objectives for regional record users. These
objectives should incorporate the needs of regional staff and
.other record users, including headquarters and the public. The
region's information needs can be assessed through discussions
with records management staff and program managers regarding
issues or problems, or direct observations regarding the use of
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records management resources. For example, under-utilization
or misuse of regional records management forms or tracking
system may indicate a lack of user understanding of records
management program objectives or the inability to incorporate
records management procedures into program operations.
Through communication with regional staff, the records officers
can pinpoint areas where additional training, information-
sharing, or, where possible, revised records management
procedures may be appropriate. The choice of commmunication
tools and the overall information strategy will depend on an
accurate and timely assessment of the intended audience.
In assessing the information or communication needs of
regional staff, the regional records management staff should
consider the broad range of records needs facing regional records
creators and users. Specifically, the records officers must
consider the needs of a particular program or management office
in order to best assist the staff in incorporating records
management into everyday practice. In addition, the
information needs of an infrequent record user, such as a
member of a Superfund site community, also need to be
addressed. These needs will change as the region's records
management program evolves; therefore, continued reviews of
the region's user population will be important to an effective
communication strategy.
Selection of appropriate communication vehicles - After
the target audience has been identified, the region should select
appropriate communication vehicles. There are various
outreach tools to be considered such as:
• Formal communications in the form of briefings
lectures, and training classes
• Informal communications in the form of group
discussions, such as staff meetings, where the
region's records management staff can share
information in a relaxed and interactive
environment
• Written information (posters, instructions, fact
sheets) either posted or distributed through
established channels, such as a regional newsletter
or orientation packets
Model Regional Records Management Manual (November 1991 draft) 187
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Records Management Program Components
• Written and audio-visual materials that encourage
regional staff to familiarize themselves with
records management procedures and polices
• On-line instruction through a LAN application
whereby staff can access records management
information and instructions.
There is a broad range of records management program
literature available through professional associations, and
Agency-specific information can be obtained through the NRMP
staff. Specific resources are provided in the attachment to this
document. Where region-specific training tools are warranted,
the Regional Records Management Coordinator may choose to
obtain contractor assistance or other technical support to design
appropriate information exchange tools.
Frequency of regional communications - Finally, regions
must decide on the frequency of communications. The Regional
Records Management Coordinator must work with records
officers and their regional manager to identify communications
needs on an ongoing basis and develop steps to address those
needs. Depending on the topic and audience, regions may use
NRMP materials and personnel or share new materials
developed by resources organizations and other regions. A list of
resource organizations is provided on the next page.
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Staff Communication
Information Resources for Records Management
Materials/Communication Tools
Administrative Management Society
AMA Building
2360 Maryland Road
Willow Grove, PA 19090
American Federation of Information
Processing Societies, Inc.
1815 North Lynn St., Suite 800
Arlington, VA 22209
American Library Association
110 Maryland Avenue, NE
Washington, DC 20002
American Management Association
135 West 50th Street
New York, NY 10020
Association for Information and Image
Managers
8728 Colesville Road
Silver Spring, MD 20910
Association for Systems Management
24587 Bagley Road
Cleveland, OH 44138
Association of Information Processing
Professionals
1015 North York Road
Willow Grove, PA 19090
Association of Records Managers and
Administrators, Inc.
4200 Somerset
Suiet 215
Prairie Village, KS 66209
Data Processing Management Association
505 Bussc Highway
Park Ridge, IL 60068
Financial Executives Institute
Ten Madison Avenue, #1938
Morristown, NJ 07960
Institute of Certified Records Managers
P. O. Box 8188
Prairie Village, KS 66208
International Information Management
Congress (IMC)
P. O. Box 34404 •
Bethesda, MD 20817
International Records Management Council
22243 Miston Drive
Woodland Hills, CA 91364
National Association of Government Archives
and Records Administrators (NAGARA)
New York State Archives
Cultural Education Center
Albany, NY 12230
National Association of Small Business
Investment Companies
1156 15th Street NW, S1101
Washington, DC 20005
National Business Forms Association
433 East Monroe Avenue
Alexandria, VA 22301
National Micrographics Associations
8719 Colesville Road,
Silver Spring, MD 20910
National Office Products Association
301 N. Fairfax Street
Alexandria, VA 22314
National Records Management Council
60 East 42nd Street
New York, NY 10065
Office Automation Management Association
440 Main Street, Suite 127
Ridgefield, CT 06877
Society for the Advancement of Management
2331 Victory Parkway
Cincinnati, OH 45206
Society for Information Management Systems
One Illinois Center
111 East Wacker Drive, Suite 600
Chicago, IL 60601
Society of American Archivists
600 S. Federal, Suite 504
Chicago, IL 60605
Special Libraries Association
235 Park Avenue South
New York, NY 10003
Model Regional Records Management Manual.
(November 1991 draft)
189
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APPENDIX A
Inventory of Records Management Studies
for EPA
-------
Appendix A
Inventory of Records Management Studies for EPA
The following is a list of recent studies supporting improvements in EPA's
records management program. The studies are presented in chronological
order.
1. U.S. Environmental Protection Agency, Region I. Development of
Improved Procedures for Records Management for Region I Superfund
Program prepared by American Management Systems, Inc. 17 October
1986.
2. U.S. Environmental Protection Agency, REM HI Program Guidelines -
Program Filing System prepared by EBASCO Services Incorporated. 12
August 1987.
3. U.S. Environmental Protection Agency. Region III. File System
Maintenance Procedures: CERCLA File Organization Project prepared
by Booz, Allen & Hamilton, Inc. October 1987.
4. U.S. Environmental Protection Agency, Region IV. Development of
Improved Procedures for Records Management for the Region IV
Superfund Program - Task 2.3: Superfund Improvement Options
prepared by American Management Systems, Inc. 8 June 1988.
5. U.S. Environmental Protection Agency. Region in. RCRA File System
Report prepared by Booz, Allen & Hamilton, Inc. September 1988.
6. U.S. Environmental Protection Agency. Office of Administration and
Resources Management. Evaluation and Design of a Microform
System for the Procurement and Contract Management Division
prepared by Booz, Allen & Hamilton, Inc. June .1988.
7. U.S. Environmental Protection Agency, Region I. Development of
Removal Program Site File Structure for Region I Environmental
Services Division prepared by American Management Systems, Inc. 18
July 1988.
8. U.S. Environmental Protection Agency, Region I. Briefing on the Draft
Superfund Removal Program Site File Structure for Region I
Environmental Services Division, U.S. EPA prepared by American
Management Systems Inc. 29 July 1988.
9. U.S. Environmental Protection Agency, Region IV. Development of
Improved Procedures for Records Management in EPA Region IV
-------
Superfund Program - Task 2.1: Requirements Analysis prepared by
American Management Systems, Inc. 2 December 1988
10. U.S. Environmental Protection Agency. Region in. Data Base
Documentation for the Region III Administrative Record File Indexing
Data Base prepared by Booz, Allen & Hamilton, Inc. January 1989.
11. U.S. Environmental Protection Agency, Removal Site Records
Management Manual Draft prepared by American Management
Systems, Inc. 8 March 1989
12. U.S. Environmental Protection Agency, Region IV. Overview of
Region V Superfund NPL Site File Organization and Administrative
Record Compilation prepared by-American Management Systems, Inc.
20 March 1989.
13. U.S. Environmental Protection Agency, Region IV. File Structure
Guidance for Region IV Superfund NPL Site Files and Superfund
Removal Site Files Version 1.2 prepared by American Management
Systems, Inc. 24 March 1989.
14. U.S. Environmental Protection Agency. Region III. Data Base
Documentation for the Region in Administrative Record File Indexing
Data Base prepared by Booz, Allen & Hamilton, Inc. January 1989.
15. U.S. Environmental Protection Agency. Region III. Administrative^
Record File Procedures for Removal and Remedial Sites Under
CERCLA prepared by Booz, Allen & Hamilton, Inc. March 1989.
16. U.S. Environmental Protection Agency, Region IV. Waste
Management Division. Superfund Records Center Operations Manual
prepared by American Management Systems, Inc. May 1989
17. U.S. Environmental Protection Agency, Office of Pesticides and Toxic
Substances. Procurement Analysis for a Document Storage and
Retrieval System prepared by Booz, Allen & Hamilton, Inc. June 1989.
18. U.S. Environmental Protection Agency, Region I. Waste Management
Division. Records Center Operations Manual prepared by American
Management Systems, Inc. June 1989
19. U.S. Environmental Protection Agency. Region III. CERCLA File
System Self-Training Course Manual prepared by Booz, Allen &
Hamilton, Inc. June 1989.
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20. U.S. Environmental Protection Agency. Office of Information
Resources Management. Evaluation of Regional Superfund Records
Management Initiatives prepared by Booz, Allen & Hamilton, Inc.
June 1989.
21. U.S. Environmental Protection Agency. Office of Information
Resources Management. Development of an Electronic Recordkeeping
Strategy and Guidance prepared by Booz, Allen & Hamilton, Inc. June
1989.
22. U.S. Environmental Protection Agency. Region V. Design,
Development and Implementation of a Records Management Program
for Region V CERCLA prepared by Booz, Allen & Hamilton, Inc. June
1989.
23. U.S. Environmental Protection Agency. Office of Administration and
Resources Management. Assessing Optical Disk Technology for Use in
PCMD Records prepared by Booz, Allen & Hamilton, Inc. June 1989.
24. U.S. Environmental Protection Agency, Region VII. Waste
Management Division. Superfund Records Center Operations Manual
prepared by American Management Systems, Inc. September 1989
25. U.S. Environmental Protection Agency. Contract Laboratory Program
Purge Files - CLP Tracking System Manual - EPA Region I prepared by
American Management Systems, Inc. 24 October 1989
26. U.S. Environmental Protection Agency, Region I. Analysis of EPA
Region I TFK Building Office's Records Management Requirements and
Development of Improvement Options - Interview Guide and Key
Areas of Responsibility for EPA Region I by Division/Program/Off ice
prepared by American Management Systems, Inc. December 1989.
27. U.S. Environmental Protection Agency. Superfund Document
Management Study - Initiation Phase Report - Preliminary Draft for
Review and Comment prepared by Roy F. Weston, Inc. 6 December
1989.
28. U.S. Environmental Protection Agency. Superfund Document
Management Study - Initiation Phase Report - Executive Summary -
Preliminary Draft for Review and Comment prepared by Roy F.
Weston, Inc. 6 December 1989.
29. U.S. Environmental Protection Agency Office of Solid Waste and
Emergency Response. Concept Phase and Definition Phase for the
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Superfund Document Management System (SDMS) prepared by
American Management Systems, Inc. 4 January 1990
30. U.S. Environmental Protection Agency. Recommendations on
Guidance for Contractors, States and Other Federal Agencies for
Document Management - Preliminary Draft for Review and Comment
prepared by Roy F. Weston, Inc. 9 March 1990.
31. U.S. Environmental Protection Agency. Development for Superfund
Indexing and Barcoding System prepared by American Management
Systems, Inc. 12 March 1990.
32. U.S. Environmental Protection Agency, Region IV. Inmagic Data Entry
and Report Production Procedures for EPA Region IV Administrative
Record Index Data Base prepared by Booz, Allen & Hamilton, Inc. 16
March 1990.
33. U.S. Environmental Protection Agency, Region I. Development of
Improved Procedures for Records Management in EPA Region I TFK
Building Offices prepared by American Management Systems, Inc. 9
April 1990.
34. U.S. Environmental Protection Agency, Region I. Region I Superfund
Site File Document Indexing System: System Concept prepared by
American Management Systems, Inc. 9 July 1990.
35. U.S. Environmental Protection Agency. Office of Information
Resources Management. Comprehensive Analysis of Records and
Forms Management Program in EPA Headquarters Offices: The Office
of the Future prepared by Booz, Allen & Hamilton, Inc. July 1990.
36. U.S.* Environmental Protection Agency, General System and Feasibility
Study for Automated Support for Superfund NPL Site Records
prepared by American Management Systems, Inc. 30 September 1990.
37. U.S. Environmental Protection Agency. Office of Information
Resources Management. Guidance for Developing Image Processing
Systems in EPA prepared by Booz, Allen & Hamilton, Inc. February
1991.
38.. U.S. Environmental Protection Agency. Superfund Indexing and
Circulation Control System - User's Manual prepared by American
Management Systems, Inc.
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APPENDIX B
"Revised Regional Information Resources
Management Model to Include Records
Management Support, " OARM/OIRM,
January 17,1989
Sample Position Description for Regional
Records Center Manager
Contractor Do' and Don'ts
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
ADMINISTRATION
iNO RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Revised Regional Information Resources Management
Model to Include Records Management Support
FROM: . Edward J- Hanley, Director
Office of Information Resources Management
' }
TO: Assistant Regional Administrators
Regions II, III, IV, V, VI, VII, VIII and IX
Planning and Management Division Director,
Region I
Management Division Director, Region X
The Office of Information Resources Management (OIRM) has
revised the Regional Information Resources Management (IRM)
Model to include records management support. OIRM recommends
that the records management function move under the authority
and direction of the Regional IRM Branch.
The increase in Superfund documentation has precipitated
the development of records management initiatives in most EPA
Regions. Many Regions plan on using the experiences learned
from the organization and design of Superfund records management
systems as a springboard for region-wide records management
programs. Currently, these Regional initiatives are coordinated
by various groups including: Administrative Services Branches;
IRM Branches; Waste Management Divisions and Superfund Program
Units. SOBM -of the Regions lack dedicated records management
professionals to direct the design, implementation and
maintenance of the initiatives.
OIRM believes that incorporating records management
support within the IRM Branch will help ease the problems of
the lack of consistency and qualified personnel. The Regional
IRM Managers network will provide an effective medium for
information exchange and technology transfer, as well as
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assuring strong management and technical direction for the
records management functio_n._ Most. imporjLan-t—e4—ail, thre—•
inclusion of records management in the Regional IRM function
will help assure integration of records with other information
resources and technologies.
I have attached a revised Regional IRM Model that
describes the records management function we believe should be
developed in each EPA Regional Office. We welcome your comments
on this Model.
If you have any questions, please contact me directly at
FTS 382-4465 or Steve Schilling at FTS 382-5636.
Attachment
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I . Introduction
The EPA Regional Offices play a critical role in the
collection, management and processing of EPA's information
resources. The EPA Regions are specifically responsible for
reporting on the implementation and enforcement of most major
Federal environmental statutes, for documenting and reporting
the transactions involved in the several billions of dollars
provided to State and local governments under EPA
administered grant programs, and for measuring and assessing
the environmental results of Federal and State programs to
protect the environment. The Regions are also responsible
for managing and reporting on emergency and remedial response
programs under Superfund, and for gathering and maintaining
the documentation required to assign responsibility for
charges to Superfund.
Due to their critical role in the Agency's overall
information resources management program, the Office of
Information Resources Management (OIRM) assigns special
importance to the development, support and assessment of
Regional information management capabilities. Over the past
several years, OIRM has assigned the highest priority to
enhancing Regional IRM programs and capabilities, including:
The modernization of Regional computing and data
communications resources.
• The assessment and strengthening of Regional IRM
organizations.
• The improvement of'State/EPA data management,
including pilot State data management initiatives
conducted by each EPA Region.
• The improvement of Regional records management
systems.
To continue assisting and strengthening Regional IRM
programs and capabilities, OIRM has developed and updated
this document for use in the Regional Offices which is
presented in the following pages. This document also includes
a current listing of Regional IRM Managers, and two summary
tables on Regional IRM Organizations and Resource trends.
OIRM will be updating this document periodically in
coordination with the Regional Offices.
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Ill. Regional Office IRM Organizational Model
In both the private and public sectors, organizations
are placing increasing emphasis on managing information as an
important corporate resource. As a result there is a
transition taking place that involves not only restructuring
the ADP organization but also implementing new management
approaches. EPA is no exception to this growing emphasis on
information resources management (IRM).
Increasingly much of the information used by EPA
originates within the State environmental organizations and
in the EPA Research and Development Program (ORD). Any
effective EPA IRM program must inherently involve the States,
ideally as co-partners. State involvement requires Regional
leadership in establishing and maintaining this EPA/State IRM
partnership. Additionally, EPA's ORD Laboratories collect
considerable amounts of information which requires effective
management. Therefore, involvement of at least the major EPA
Laboratory sites at RTP, Las Vegas and Cincinnati is also
important for a successful EPA IRM program.
OIRM promotes the continued strengthening of the
Regional Management Divisions and their RTP, Las Vegas and
Cincinnati counterparts. OIRM recommends the following
functions for inclusion in a Regional IRM organization:
Overall IRM Branch and Section Management
— Branch management and secretarial support
Support to Regional Office IRM Steering
Committee
Improvement of communication with IRM services
user community
Development and implementation of
Regional/State IRM Plans
- Review of State grants and programs relative
to IRM support
Oversight of all on-site IRM contractor
support.
• Central ADP Operations and Support
- Operate Computer Center
Modernize ADP technology in'the Regional
Office.
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• Software Development and Management
- Provide ADP systems management
- Assist EPA Headquarters in developing National
and—Agency-wide systems .
An additional function for the IRM Branch in this
area could also be:
Lab Automation.
• Information User Services
Operate Information Center
Support office automation, electronic mail and
word processing
Operate Library
Support Information Security.
Additional functions for the IRM Branch in this
area are:
Operate Public Information Center
Operate Regional Map Center.
• Records Management Support
Operate Records Center fsl
Develop Records Management Life Cycle Systems .
• Voice, Image and Data Telecommunications
• Comprehensive Environmental Data Management
Develop data integration systems
Provide Data Base Broker Services.
A brief description of the envisioned scope of these
functions follows.
Overall IRM Branch and Section
In addition to Branch management and secretarial
support, other functions in this category include:
• Support Regional Office IRM Steering Committee —
At the Headquarters level, the Administrator has
established an EPA IRM Committee. this Committee
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is chaired by the OIRM Director. OIRM recommends
that similar Committees be established in each
Regional Office chaired by the ARA/Management
Director with the Regional IRM Manager serving as
the Executive Secretary to the Committee.
Improve Communications with IRM services user
community - Good communications and public
relations between the IRM organization and the user
community it supports are essential for a
successful IRM organization. The objective of
these regularly scheduled meetings is to keep the
users informed of both Regional and Headquarters
IRM plans as well as obtaining user input to these
plans and feedback on IRM service delivery.
Develop and implement Regional/State IRM plans —
Each Region should continue to refine and augment
their Regional/State IRM plan. The EPA
Administrator assigns a high priority to improving
EPA/State data management. OIRM believes that
leadership provided by the Regional IRM
organization in drawing together Regional and State
senior program and ADP managers to improve EPA
information systems is critical to further success
in this area.
Review State grants and programs relative to IRM
support - The Regional Office IRM organizations
need to review EPA program grants to the States to
be sure funds that will support IRM are consistent
and compatible with Regional/State IRM plans. In
addition to reviewing grants, the Regional IRM
manager should periodically visit the State
environmental agencies to review the delivery of
IRM services to EPA delegated environmental
programs.
Oversight of all on—site ADP Contractor Support —
Over the years EPA has used contractors for data
handling support. These contract resources are
funded and managed by multiple project officers.
Often the project officers are located at EPA
Headquarters and the contractor staff are located
in the Regional Office. To maximize contractor
productivity and service, the Regional Office IRM
manager should oversee all the on-site contractor
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data handling staff in coordination with all the
project officers. OIRM is not recommending that
the Project Officers assignments be changed but
rather that the Site Manager have overall
accountability to one EPA on-site manager, the IRM
Manager.
Central ADP Operations and Support
All Regional Office IRM Branches/ADP Sections
currently operate the central computer equipment,
run production jobs, provide data entry services
and distribute computer output. Over the next few
years there will be a significant modernization of
the Regional Offices computing resources which must
be carefully managed to assure a successful
implementation and uninterrupted support to users.
A strong Regional Office technical staff will be
key to successful implementation fo EPA ADP
Modernization Plans.
Software Development and Management
• Provide ADP Systems Management - All the Regional
Office IRM Branches/ADP Sections currently perform
this function to some degree which includes support
of National systems (e.g., systems used by EPA and
the States...STORET, GICS, PCS), of Agency-wide
systems (e.g., EPAYS, FMS, FRDS) and development of
local systems. As the large National and Agency-
wide systems are modernized, the Regional Office
ADP staffs will play a central role in implementing
system changes in the Regions and in the States.
There is considerable variation as to the degree of
centralization of this function within a Regional
Office. OIRM's observations are that the highly
decentralized situation does not work well,
primarily because the Regional Office would not
have the "critical mass" of program systems ADP
expertise required to not only adequately support
the Regional Office but also to do the essential
coordination and planning with the States. OIRM
recommends a more centralized approach that places
the "critical mass" of staff with strong ADP
experience in the IRM Branch. This also includes
the staff that would perform the more complex data
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retrievals that are generally beyond the
capabilities of the average end-user.
Assist Headquarters with National and Agency—wide
Systems Development - OIRM sees the need for the
Regional Office IRM Managers to play a more formal
and proactive role in working with Headquarters EPA
National and Agency-wide Systems Managers in
developing and enhancing these systems.
Traditionally the Regional Offices have, to varying
degrees, provided comments on the design and
participated in the testing of these EPA systems.
OIRM wants to increase the participation of these
offices in National systems development through
more formal involvement of the senior Regional
Offices' IRM professionals. OIRM recommends a
concept where OIRM formally recognizes senior
Regional IRM professionals, based upon their
expertise, to work closely with the National and
Agency-wide Systems Managers in systems
development. This would include coordination and
advising on the system design and implementation on
behalf of all Regional Offices plus independent
beta testing and acceptance of all system changes
in their Regional Office before Agency-wide
implementation. OIRM will provide official
recognition of expert status to selected
individuals who have established an outstanding
"track record" at the National level in this
regard. OIRM recommends that this expert status be
reflected in the individual's Position Description
and grade classification.
Support Laboratory Automation — Many of the
Regional Environmental Services Divisions use mini
and mainframe computers for laboratory data
management and other tracking systems. This type
of ADP support is considered as part of "ADP
Systems Management" presented above. Several of
the Regions are seriously considering the
implementation of the standard Laboratory
Instrumentation Management Systems (LIMS) which
will ultimately enable data to be recorded,
analyzed, reported and transferred to the large
Agency data bases (e.g., STORET) with far greater
efficiency and quality. The implementation of LIMS
will be a key aspect of EPA laboratory automation
and modernization. Because of the need for both
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ADP expertise together with knowledge and
interaction with the Agency's major program
systems, OIRM sees advantages in assigning
laboratory automation support to the IRM Branch.
At the National level, OIRM is responsible for the
acquisition of LIMS.
Information User Services
Operate Regional Office Information Center - The
purpose of the Information Center is to help end-
users do their own computing. The services of an
Information Center can include consulting (e.g.,
providing managers recommendations on office
automation), training (e.g., Electronic Mail,
Lexitron, PCs, PRIME, ADABAS/NATURAL) , providing
technical assistance (e.g., helping an end-user
develop a LOTUS 1-2-3 spreadsheet application),
performing the file server role (e.g., finding the
automated data and transferring it into a suitable
format for the end-user), and troubleshooting
problems that end-users are unable to resolve
themselves.
The Information Center will provide the primary
support for implementing and maintaining personal
computers (PCs) and providing IRM training in the
Regional Office. Encouraging end-user computing is
important because it can improve personal
productivity and decision-making and also conserve
the ADP professional staff for more technical and
complex projects.
Support Office Automation. Electronic Mail and Word
Processing - OIRM views this support as part of
the Information Center functions described above.
Some Regional Offices currently have this support
split between the ADP and Administrative'Services
function. As the office automation, the
telecommunications and the traditional ADP
computing environments become more and more
integrated, OIRM believes that it is critical that
this support be provided by the IRM organization.
Operate Regional Office Library - The Regional
Offices have traditionally operated libraries and
generally, the library was separate from the ADP
-------
organization. Changing technology is resulting in
increased use of automated data bases by libraries.
The EPA Libraries are retrieving data from non-EPA
systems just like the ADP organizations are
retrieving data from EPA systems.
Support Information Security — Technological
advances are having a significant impact on
information security and records management. An
ever increasing amount of information is being
stored in electronic form (e.g., Lexitron and PC
diskettes, PC and PRIME hard disks) which is
prompting many managers to rethink procedures and
controls for storing information.
Operate Regional Public Information Center - At
Headquarters and in Regions VI and IX this function
is part of the IRM organization. At these
locations, the function is closely associated with
the library which also provides information to the
public.
Operate Regional Map Center — In Region II this
function is managed by the IRM organization. The
centralized map room is located adjacent to the
Regional Computer center which produces map
overlays showing pollution sources and other
relevant data in EPA and State systems. OIRM
recommends that, where practical, the Map Center be
an extension of the Library.
Records Management Support
OIRM recommends that the records management function be
centralized and coordinated by the Regional IRM Branch. All
Regions have initiated or implemented a Superfund Regional
records management program and foresee expanding the use of
records management techniques into other programs.
Coordination of the records management function by.the
Regional IRM Branch will help reduce duplication of efforts
by programs by providing the structure for communication of
previous efforts and new technologies. Regions are currently
addressing records management in a variety of ways:
8
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Operate Records Center(s) - Region IVs
initiative to create a centralized records center
and Region VI's implementation of a centralized
program records center, are managed by the IRM
Branches. Region II has a similar Records Center
managed by the Permits Administration Branch which
is part of the Management Division. Regions I and
III have established centralized records systems
managed by the Superfund program. Region X is
planning a records management system coordinated by
the Superfund program. Regions V and IX are
organizing documents under the direction of the
Waste Management Division. Region VIII is
implementing a Superfund records management system
led by a Special Superfund Coordinator in the
Assistant Regional Administrator's office. The
Program Integration Branch, under the direction of
the ARA, in Region VII is planning a records
management system. Many of the initial efforts to
design and implement a records management system
were driven by the immediate needs of the Superfund
program which has rapidly increasing volumes of
documentation and legislated demands such as the
Administrative Record and cost recovery.
Records management is the foundation for numerous
other information systems and requires dedicated
personnel (FTEs) to effectively carry out tasks
associated with creation, classification,
maintenance and disposition of records. As a base
each Region should have at least one FTE dedicated
to records management. Additional FTEs or
fractions should be added based on: the size of
the Region, number of NPL sites, the current state
of records management, the future records
management plans (advanced technologies') and
anticipated office moves.
Records Management Life Cycle - The life cycle
approach to records management, which focuses on
the management of records from their creation
through their maintenance, use and disposition, has
been a primary operating procedure for several
years. There has been a new emphasis on the
records management life cycle because of the high
growth rate in records volume and the permanent
nature of Superfund records. Several different
approaches to the records management problem have
-------
been tried in the Regions with great success .
These initiatives focused on records capture,
classification and records control. Records
capture entails the steps to ensure that all
appropriate and relevant documentation is included
in the records management system. Records
classification involves methods for categorizing or
classifying documentation. Records control
involves the steps taken to ensure that integrity
of files is maintained and that they are disposed
of as necessary. Together, these processes help to
effectively manage records. Detailed information
on the status of records management programs within
the Regions can be obtained from QIRM.
Voice. Irr.agg and Data Telecommunication and Networking
Telecommunications is extremely important to the
operations of EPA. The Regional Office IRM organizations are
playing a critical role in the modernization of the EPA data
telecommunication network. This is particularly true as the
network is extended out to the States.
Currently, most IRM Branches/ADP Sections are
responsible for data communications but not for voice and
image (e.g., facsimile) communication. As communications
technology continues to quickly evolve, common technical
solutions are now being employed to support data, voice and
image communication. For example, the same wires and multi-
wire cables used to connect the telephones can be used
concurrently for connecting PCs to local computers. This
becomes more significant as the Agency moves toward computer
workstations on every desk. Also, this type of technical
expertise is in short supply and the resources available in a
Region to perform this function are small. Therefore,
consolidating the responsibilities for data, voice and image
communications can be advantageous from both a technical and
resource standpoint. At the National level these functions
are now consolidated in the National Data Processing Division
(NDPD).
("!omnrf>hgngiv£ Environmental Data Management
^™^™™——^™^"'^™—™^—^^^^B^^*^"^™l^^^™™™'^"^™^~^™™^^"™^"—™^*^~^^"—^~"^™^^^^™™•^•^^™"—^™^^^™^^"^^^™^^
Region IV recently implemented an Office of Integrated
Environmental Analysis (OIEA) to develop data integration
techniques to support both Regional and State program
offices. OIEA works closely with its sister organization,
10
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the Information Management Branch to perform the functions
described below. Overall coordination for these functions is
provided by the ARA for Policy and Management.
• Develop Data Integration Systems - The Regional
Offices have a history of investing resources in
innovative approaches to integrating, analyzing and
displaying information in National systems. Some
examples are Region VIII's Environmental Index
Project, Region II's Facilities Index and
Environmental Mapping Systems and Region IV s
recent geographic information systems efforts.
These projects usually cut across EPA and State
organizational lines, are multidisciplinary in
nature and receive varying degrees of support from
Headquarters offices. OIRM recommends that the
Management Division, due to its involvement with
all programs, be the focal point for at least the
management of the IRM aspects of these projects.
This is consistent with OIRM's responsibilities at
the National level where the environmental systems
integration responsibilities are assigned to OIRM's
Program Systems Division. OIRM seeks a very close
and productive working relationship between the
Program Systems Division and those Regional Offices
which implement data integration systems that have
potential National application.
• Provide Data Base -Broker Services — The future
successful and widespread use of environmental data
integration systems will depend greatly on the data
base quality and accessibility. This is a complex
area because there is a considerable amount of
useful, automated environmental data but generally
it is very decentralized. Within EPA, much of
these data are available on either the NCC-IBM or
Sperry Computers but the data bases are managed by
many different people and organizations. Also the
EPA data represents only a portion of what is
available. Other potential data sources are USGS,
SCS, NOAA, Census Bureau, State and local
governments, interstate agencies and commercial
. sources (e.g., Dun & Bradstreet) . Advising
Regional and State staffs on what automated data is
available, who to talk to about data quality and
how to obtain access to the data are functions that
need to be performed by a Data Base Broker. For
those non-EPA centralized data bases that are
1 1
-------
needed by Regional and State staffs on a regular
basis, the Data Broker would also develop
arrangements for these data bases to be more
readily available (e.g., updated copies made
available on the EPA central or Regional
computers). OIRM recommends this function be
assigned to the Regional IRM .organization and,
further, that it be closely allied with the Library
and Information Center functions. In addition to
brokering access to automated data bases outside of
EPA, OIRM recommends that the Data Broker
facilitate the resolution of cross-system data
quality issues within the Region. For example,
establishing uniform facility naming conventions or
negotiating commitments from individual system
managers for completion of latitude-longitude data.
12
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INFORMATION MANAGEMENT SPECIALIST
GM-301-14
I. INTRODUCTION
This position is located in the Office of Administration
and Resources Management, Office of Information Resources
Management, Information Management and Services Division,
Information Access Branch.
The Information Management and Services Division (IMSD)
is responsible for formulating and implementing the Agency's
Information Resources Management program to manage and •
enhance the collection, reporting, storage, manipulation,
analysis, and use of records generated by EPA. The mission
of the Information Access Branch (IAB) is to disseminate and
provide access-to environmental information. IAB is
responsible for leadership and service in providing
environmental information to EPA staff, managing access to
EPA records and providing public access to EPA information
sources. Efforts are directed at improving the availability,
accessibility, timeliness, and usefulness of information.
IAB responsibilities include assessment of Agency need and
public demand for information, and definition, creation,
implementation and maintenance of effective programs for
providing information, including coordination of libraries,
public information contacts, dockets and records centers in
Headquarters, Regions and laboratories.
The primary purpose of this position is to provide
policy development expertise and senior analytic support to
the Branch Chief in assessing and defining the needs of
Agency managers for records management, and developing and
implementing effective programs for meeting those needs. A
major function of this position is to serve as the primary
liaison with the Office of Emergency and Remedial Response
(OERR) to provide consultation, technical advice and
implementation support for managemento fo OERR records in
Headquarters and Regional offices.
II. MAJOR DUTIES
The incumbent has primary responsibilities for
developing and implementing a strategy for revitalizing
records management functions.consistent with Office of
Management and Budget Circulars A-130' on establishment of
Federal Information Resources Management (IRM) Programs. The
incumbent establishes Agencywide policies, procedures, and
guidance in several specialized areas of information
management, including archival management, vital records
management, document creation and maintenance, training, and
other advanced office management information and
documentation systems. The incumbent is responsible for
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planning, organizing, and directing studies, surveys, and
special projects in these areas, and for developing and
coordinating Agencywide program audits and evaluations.
These studies and program evaluations include analysis of
information needs to design new or modified documentation
systems, and assessment of the_-eJ: f icieney -of enisling "systems'
in accomplishing management objectives.
Negotiates with officials at the various organizational
levels involved during the conduct of studies, and seeks
their approval or comment on the preliminary and final study
conclusions and recommendations. Many of the operating
procedures and systems under study are interrelated with
those or other organizations or systems. These must be
coordinated or adjusted with the organizations or systems
managers involved. The incumbent is required to present oral
and written study findings and recommendations to a broad
range of Agency officials. Provides technical assistance and
training- to program officials during the implementation of
the recommendations.
SPECIFIC RESPONSIBILITIES OF THE 'INCUMBENT ARE AS FOLLOWS:
1. Program Planning. Keeps abreast of legislation and
regulations administered by and imposed upon the EPA and
studies their effect to determine the objectives and
obligations of the Agency. In relation to the Agency
requirements, conceives and determines the nature and
dimensions of the management functions necessary to keep pace
with new developments and changes in Agency programs,
functions and organizational structures. Establishes
objectives to be attained in information management program
areas. Plans the conduct of surveys to respond to requests
assistance. Initiates periodic evaluation surveys in the
various Agency organizations. Formulates and recommends
policies that will achieve these objectives, maintaining
liaison with line managers^ on matters of mutual interest
concerning requirements. ^Assumes responsibility for
integrating records management into a complete and
comprehensive program, and for developing immediate and long-
range plans this area.
2. Program Implementation and Administration. -Provides the
records management staff with policy guidance and the
framework for the further detailed development,
implementation, and operation of the various aspects of
program area. Reviews implementation plans developed by
staff members ensuring completeness of coverage, determining
emphasis needed on specific areas, and otherwise ensuring
that these plans are realistic and appropriate in relation to
Agency needs and objectives and the capabilities of the staff
to provide assistance. Maintains liaison with other
-------
Government agencies to exchange information and ideas with
view to keeping abreast of the state of the art and
installing modern practices and innovations.
3. Program Appraisal. \ Establishes and directs and system
for the evaluation of records management practices to
determine the overall effectiveness of the program throughout
the EPA."^1 Analyzes survey findings, reports, and other
documents concerning effectiveness of program; identifies
strengths and deficiencies in the various areas, and
recommends appropriate improvements.
4. Program Services. Provides direction to Records
Management Staff engaged in day-to-day services. This
includes records retirement and retrieval, review of file
equipment requests, procedural guidance to secretaries and
file clerks, and interpretation of records procedures. Keeps
in touch with status and progress of work and adjusts
priorities when necessary, maintaining balance between
Headquarters service and Agencywide management.
5. Information Resources Management Plans, develops and
coordinates a certification program which delegates records
management functions to EPA program and regional offices and
establishes a records management program integrated with
EPA's IRM program and policies. Designs and conducts a
program for certifying records management officers as a basis
for delegation. Training may be provided by the incumbent,
other Agency personnel or contractor/consultants. ^Develops
tools promoting the effective coordination of decentralized
-records management activities, e.g., automation of the
retention and disposition schedules processes, tp ensure the
accessibility and security of EPA information^ iProvides
advice and technical assistance to records management
officers on IRM policy and the interpretation of all related
Federal laws, regulations and guidelines. Serves as the
project manager on studies to resolve IRM~^issues in records
management and advises senior Agency managers and the IRM
Steering Committee on all matters related to records
management.
6. Vital Records: Develops, coordinates, and conducts
Agencywide comprehensive studies of vital records management
programs which provide for the immediate and sustained
operations of EPA in the event of a national emergency or
national disaster. Maintains liaison with program officials
to determine their emergency information and documentation
requirements and provides technical assistance concerning the
preservation of this information at a protected site.
Develops EPA issuance providing procedures and instructions
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designating these vital information resources and specifying
the optimum media for storage at the site.
7, 'Creation and Maintenance, of Records Develops and promote
an Agencywide program for the creation and maintenance of the
Agency's records. Establishes control and provides guidance
to program officials to insure that important policies and
decisions of the Agency are adequately recorded, routine
operational documentation is kept to a minimum, and the
accumulation of unnecessary documents in prevented.
Provides guidance to program officials to insure there
are effective management controls over the maintenance and
use of information. Specifically, studies analyzes, and
provides recommendations concerning the selection of the most
efficient and cost-effective storage and retrieval equipment
for all types of information documentation systems, including
information systems. All systems are evaluated to determine
if the reference and retrieval requirements justify automated
or semiautomated storage equipment.
SUPERVISORY CONTROLS
Receives general direction from the Chief, Information
Access Branch, in the form of broad guidelines, policy, and
program objectives, and completion time constraints of the
project assignment. Work is reviewed to determine
accomplishments as reflected in reports, management
assistance, advice, and counsel provided to Agency managers
and conformance with the Federal Records Act of 1980, as
amended, and Executive Order 11921, as implemented by 41 Code
of Federal Regulations 101.
-------
CONTRACTOR DO'S AND DON'TS
-Developing the Work Assignment
DO: Clearly define the type of work to be done and any
specifications or standards to be adhered to
DO: Include the following information in the work
assignment:
A work assignment number
A title
A brief description of the work to be performed
An estimate of the period of performance
A statement of work.
Preparing the Statement of Work
DO: Clearly define the scope of the work involved and
specific products the contractor is expected to provide.
DO NOT: Assume that the contractor will do the expected work;
the work must be clearly defined and described.
Reviewing the Contractor Work Plan
DO: Review the work plan to ensure that it contains:
• An overall plan to accomplish the assignment
• A timetable for completing the assignment
• Anticipated problems within the assignment
• A detailed listing of contractor personnel
devoted to the assignment
• The hours expended by each member of the
contractor team
• A listing of all other direct costs and the total
cost of the assignment
• Detailed resumes of the contractor personnel
on the assignment.
-------
CONTRACTOR DO'S AND DONTS continued
Providing Technical Direction
DO: Provide the contractor with any additional, requested
technical guidance.
DO NOT: Modify the scope of the work plan. Only the
Contracting Officer has the authority to alter the
scope of a work plan.
DO: Contact the Contracting Officer if you have any
questions regarding your interpretation of the
work assignment.
Tracking Contractor Progress
DO: Monitor the contractor's performance on a
regular basis.
DO: Maintain regular communication with the
contractor.
DO NOT: Rely solely on written monthly reports for
progress information.
DO: Monitor the contractor's work.
DO NOT: Manage the contractor's work.
Reviewing Monthly Progress Reports
DO: Ensure that the contractor provides comprehensive
monthly reports including a technical progress report
and a financial progress report.
Quarterly Reviews
DO: Cover all issues relating to the progress of the
work assignment, especially any problems that
may have arisen during the review period.
-------
CONTRACTOR DO'S AND DONTS continued
Reviewing Invoices
DO: Review all invoices carefully and verify that all
charges are acceptable and relate directly to the
work performed during the billing period.
DO: Review all invoices in a timely manner.
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APPENDIX C
Applicable Guidance Report
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INFORMATION RESOURCES MANAGEMENT
'-r 401 M STREET S.W.
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MODEL REGIONAL RECORDS
MANAGEMENT OPERATING
PROCEDURES MANUAL
APPLICABLE GUIDANCE REPORT
November 1991
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TABLE OF CONTENTS
I. Executive Summary 1
II. Approach
III. Summary of Documents 5
IV. Appendix • 13
Applicable Guidance Report
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I. EXECUTIVE SUMMARY
In order to develop an understanding of the factors affecting the Regional implementation
of records management procedures, Booz» Allen & Hamilton Inc. conducted a review of current
EPA policy and guidance documents, as well as relevant records management studies, Federal
statutes, and National Archives and Records Adminisffatkm (NARAXana ueneral Services
Administration (GSA) instructional materials. These documents were reviewed to determine their
relevance to 13 specific records management issues, such as budget constraints, security, public
access, the records life cycle, and technology options. The results of this review provided the
groundwork for determining the relationships between existing Regional records management
practices, mandated requirements, and a model Regional records program (which will be
developed and described in forthcoming deliverables).
This initial document review revealed that for many areas of records management,
requirements, and in some instances procedures, are clearly defined. Examples of these areas
include procedures for records disposition, equipment acquisition, and Freedom of Information
Act (FOIA) requests. NARA and GSA guidance also provides extensive information on creation,
maintenance, and use of electronic records. However, most of these documents rely on the
assumption that a comprehensive records management infrastructure already exists, and that the
reader has a basic knowledge of records management principles . In many of EPA's Regional
offices this is not the case. Several of the Regional offices are in the beginning phases of their
records management programs and require additional "hands-on" information to support the
creation and maintenance of a program.
Additionally, several of the EPA-specific documents, particularly the Records Management
Manual, contain dated information which no longer reflects requirements mandated by NARA,
GSA, and a changing records management environment and information that does not depict
current Regional records management practices and needs. Furthermore, the existing records
management guidance is incomplete in that it does not provide adequate detail on certain records
management issues.
Specifically, the following areas were either not addressed or were not adequately covered
in existing records management guidance:
• Practical steps for initiating a Regional records management program
• Detailed records center structure and operations procedures
• Management support for the vital records and security programs
• Budgeting and planning information and support across programs
• Specific guidance for training in records management principles and technological
applications
• Requirements and procedures for handling cross-program issues
• Guidelines for dealing with increasing public access requirements
• Guidance for selection and use of technological applications
• Disposition schedules that reflect actual file structures.
Applicable Guidance Report
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Executive Summary
For a model Regional records management program to be successfully designed and
implemented, these areas must be further defined. Additional information gathered with regard to
specific Regional needs in these areas will allow incorporation of these elements into the
development of a model Regional records management program and its Records Center operating
procedures.
Applicable Guidance Report
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II. APPROACH
Background
i
During the last two years, EPA's Office of Information Resources Management (OIRM)
has been examining the organization and functions of both Headquarters and Regional records
management programs. As a result of this examination, OIRM has determined that Regions would
benefit from additional guidance to assist the program offices in implementing records management
activities. Booz» Allen & Hamilton Inc. is helping OIRM in this effort to provide Regions with
records management assistance through developing a model for a Regional records management
program, including a Records Center and then, subsequently, a Model Regional Records
Management Operating Procedure Guidance Document. This Document is intended to enable
managers to develop a coordinated and consistent, region-wide approach to records management
and to develop Regional Records Centers.
Purpose of Report
This document, the Applicable Guidance Report, is the first step in the completion of the
Operating Procedures Guidance Document. This purpose of this report is twofold. First, the
report provides an initial understanding of many of the functional issues which impact the Regional
implementation of records management procedures. This understanding was obtained through a
review of current EPA and other Federal government policy, guidance documents, and records
management studies and is conveyed in the report on a document-by-document basis. Secondly,
this report evaluates this body of documents and identifies functional areas for which the present
policy and guidance available to the Regions could be improved. This identification provides focus
for remaining tasks through highlighting primary areas of concern which need to be reviewed in
depth for inclusion in the Operating Procedures Guidance Document.
Approach to Report
The approach to completing this report involved three phases. The first phase centered
around the review of the previously mentioned EPA and other Federal government documents.
The documents that were reviewed in this section are listed in the Appendix. These documents
were reviewed to determine the information they provided on relevant records management issues.
These records management issues were identified, as a result of discussions with OIRM, to be the
following:
• Budget Formulation/Constraints -- the financial resources necessary and/or
available for implementation of the records management program
• File Inventory/Structure -- the organization of the records or files in terms of the
regulatory or program requirements
• Security -- the safeguarding of the Agency's information resources
• Vital Records — the protection of those records critical to the continuation of the
Agency's essential services in an emergency
• Public Access - ensuring that records storage procedures are consistent with the
requirements of the Freedom of Information Act (FOLA) and other regulatory
requirements for public access to certain documents
Applicable Guidance Report
-------
Approach
• Staffing — personnel resources needed to support the records management program
and the definition of the necessary skills and functions that are incorporated into the
staffing plan
• Space, Equipment, and Materials -- capital resources necessary, including the GSA
space requirements, OARM guidelines regarding the purchase of storage equipment
and records handling materials, and other considerations in determining the mix of
space and equipment needed
• Records Center Structure and Functions — the design and primary responsibilities
of the file room or "records center" as defined by Agency program needs or
regulatory requirements
• Life Cycle Functions ~ the requirements of the records management program as
they apply to the stages of the record's existence, from creation, through use of the
record and ultimately, record disposition/archival
• Organizational Options -- the options for integrating the program needs with the
Agency's operating structure, including the responsibilities and involvement of
upper-management staff
• Technology Options -- the options for applying technologies to accomplish
recordkeeping functions and the appropriate mix of technologies, as well as
guidelines for the creation of innovative technology applications to meet special
program needs
» Cross-Program Information Integration -- the interaction of Agency program data
and the subsequent impact of such on the structure and functions of the records
management program
Training - the background skills development and ongoing instruction necessary to
instill the appropriate mix of skills for the records management program staff.
The document reviews are presented in the Appendix of this report. Each review covers one
document and is structured in two main sections: Document Overview and Applicability to
Regional Records Management. The Document Overview section conveys general information
about the contents of the document and the audience for the information. The Applicability section
is divided into the previously mentioned records management categories and describes the type of
information found in the document for all relevant categories.
After the review of the individual documents was completed, the second phase of this
report began. This phase involved examining the collection of documents as a whole to specify
strengths and areas for improvement as they related to the records management issues. This
examination included identification of issues which were not covered sufficiently by the existing
guidance and areas for which the existing information was satisfactory. This phase also drew
upon the information provided in the records management studies. These studies offered the
perspective of several regions with regard to their records management experiences and needs.
In the final phase of this report, the information obtained in the first two phases was used
to target the records management issues about which additional information needs to be gathered in
subsequent components of the study. Gathering this information will allow these issues to be
factored into the development of the Model Regional Records Management Operating Procedures
Guidance Document.
4 Applicable Guidance Report
-------
III. SUMMARY OF DOCUMENTS
In reviewing the resource documents selected for this project, attention was focused on
the basic administrative and legal requirements provided for in the guidance, directives, and policy
developed by NARA, GSA and EPA; these requirements were considered in context with the topic
areas introduced in the Approach section of this report. These topic areas include identified
Regional records management program requirements and the procedures that support a Regional
Records Center.
While the majority of the documents reviewed for this project, under the heading
"Directives/Guidance," contain legal and administrative requirements for conducting records
management, various studies and other resource materials, which provided information on the
practical application of these requirements, were also reviewed and appear under the heading
"Studies/Other Resources." These documents either apply subjective analysis to existing
programs, or provide element(s) of the framework necessary to manage EPA's records.
The following sections include a general evaluation of the applicability of guidelines on
which to base the development of a model Regional records management program. Exhibit-1 is a
graphic representation of the topic areas covered by each document.
Directives/Guidance
Budget Formulation/Constraints
No significant information on this topic area was included in the documents reviewed.
File Inventory/Structure
A NARA guide published in 1988 contains questions designed to help records
management personnel develop and maintain an effective filing system that promotes prompt
retrieval of records. Another questionnaire is designed to help save costly storage space by
identifying non-record material. Public access regulations found in the FOIA manual and
Superfund Administrative Record guidelines mandate the existence of an inventory of existing
records series.
Vital Records
The EPA Records Management Manual and the Revised IRM Model define vital records
and the purpose of the vital records program and delineates the responsibilities of key personnel.
Various NARA publications define a process for identifying vital records, and provide guidance on
methods of vital records maintenance.
Security
The Information Security Manual implements the Agency's security policy, addressing
availability, integrity and confidentiality, specifically outlining minimum security controls for
computer installations. NARA rules and GSA guidelines on electronic records management outline
requirements for electronic records security, including restricted access, backup and recovery
mechanisms. An OMB Bulletin provides guidance for the development of security plans for
computer systems, including training and technology approaches.
Applicable Guidance Report
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EXHIBIT - 1
DOCUMENT REVIEW SUMMARY
CATEGORY
DOCUMENT
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Agency Records Management Evaluation
Electronic Records Management Final Rule
Electronic Recordkeeping
EPA Information Security Manual
Establishing and Managing a Records
Management Program
Evaluating a Vital Records Program
Evaluating Fries Maintenance and Records
Disposition Programs
Executive Order 12656 - Assignment of
Emergency Preparedness Responsibilities
Federal Archives and Records Centers
Forms Management
Freedom of Information Act Manual
Information Resources Management Policy
Manual
Information Resources Management
Strategic Plan
Applicable Guidance Report
-------
EXHIBIT - 1
DOCUMENT REVIEW SUMMARY
CATEGORY
DOCUMENT
TITLE
Budget Formula
Constraints
nventory
Recor
Access
Publ
Space. Equip
Materials
Records Cente
and Functions
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Cross-Prog
Integration
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Instructional Guide Series: Managing
Audiovisual Records
Instructional Guide Series: Managing
Cartographic and Architectural Records
Instructional Guide Series: Managing
Electronic Records
Interim Guidance on Administrative Records
Selection of CERCLA Response Actions
Micrographics 36 CFR Part 1230
Records Management Handbook:
Disposition of Federal Records
Records Management in the EPA: An
Overview for Regional Managers
Records Management Program Field
Evaluation. Environmental Protection Agency
Region 4
Records Management Regulations:
Final Rules
Revised Information Resources
Management Model
Study to Evaluate Regional Superfund
Records Management Initiatives
Superfund Document Management
Study - Initiation Phase Report
Svstem Life Cycle Guidance - 9028
vnai Records During an Emergency 36 CFR
Part 1236
Applicable Guidance Report
-------
Summary of Documents
Public Access
FOIA regulations document the policies that must be followed in determining what
information may be released, what procedures must be followed to track and file the request, and
what fees may be assessed. Guidance document^ on Electronic Recordkeeping address the
regulation3~|oveming proper controls over classified or proprietary information stored
electronically.
Public access rules particularly influence the requirement for Regions to have a structured
organization of all program files to enable access to requestor-specified records.
Staffing
GSA provides guidelines on establishing a management program for electronic records,
including general responsibilities for both managers and staff; minimal guidance is available on
electronic records responsibilities of EPA staff members. The EPA OIRM records management
manual describes general responsibilities of staff members in many areas.
The GSA forms management handbook outlines particular skills required by forms
management staff, and provides criteria for determining the size of staff needed to support a
program.
Space, Equipment and Materials
Various guidance documents outline general procedures for the acquisition of filing
equipment and supplies; the majority of the guidance materials simply suggest factors that should
be considered prior to purchasing new equipment, provide guidelines for determiningjequirements
for electronic equipment and supplies, as well as establishing minimum environmental standards
for maintaining microform and other equipment.
Records Center Structure and Functions
No information on this category was included in the guidance documents reviewed.
Life Cycle Functions
Numerous guidance documents give some degree of attention to providing objectives and
suggesting general responsibilities for the basic records management life cycle functions.
Requirements for the creation and use of data files in electronic format are found in
NARA and GSA guidance. Numerous documents, including NARA rules, outline requirements
for creation, use, indexing and retrieval, retention and destruction of electronic records.
Extensive documentation exists on the disposition requirements for all Federal
government records, including cartographic, microform, audio-visual, and electronic data.
Applicable Guidance Report
-------
Summary of Documents
Organizational Options
Various documents addressing security and vital records propose management and
organizational structures to oversee these functions. Similarly, discussions in several electronic
recordkeeping documents provide guidance on establishing a management structure, detailing its
place in the organizational hierarchy. The Records Management Manual suggests responsibilities
for various offices throughout EPA.
Technology Options
A GSA document on electronic recordkeeping discusses advantages and disadvantages of
data base management systems and full text retrieval systems as options for indexing and retrieval
functions. The OIRM Records Management Manual provides information on justifying the need
for a micrographic system; it also includes articles on optical disk, computer-assisted retrieval
systems, and image management systems. OIRM has granted approval for the Superfund
Administrative Record file to be maintained on microform.
Automation devices currently available for forms design, composition, and typesetting are
discussed in the GSA forms management handbook. The NARA rule on electronic records
management states that Federal agencies should define their requirements for selecting appropriate
maintenance and storage technologies.
Cross-program Information Integration
A recent NARA rule on electronic records management suggests that standard interchange
formats between various agency systems should be developed. OIRM policy states that data
standards should be set to provide consistent definition of data and facilitate cross-media use of
data.
Training
Executive Order 12656 Assignment of Emergency Preparedness Responsibilities
discusses the need for training and education programs that incorporate emergency preparedness
(security/vital records). Published Rules on electronic records management call for training
appropriate agency personnel to safeguard sensitive or classified records, as well as training in the
operation of media used in a system. The EPA Information Security Manual states that OARM is
coordination the development of information security training programs for the Agency.
Records Management Studies/Other Resource Materials
Budget Formulation/Constraints
The IRM Strategic Plan provides priorities and goals within the IRM arena and identifies
some funds (e.g., grant funds) that are available to support attainment of the long-range IRM
goals.
In a study done to evaluate Regional Superfund records management initiatives
discussions of budget formulation for the planning stages are summarized and funding sources and
options used by the Regions are presented. Resource constraints experienced by the Regions are
Applicable Guidance Report
-------
Summary of Documents
addressed, as are budget constraints affecting the outlook for the program as OIRM plans for
anticipated needs.
File Inventory/Structure
Regional studies characterize the features of the Superfund program and other program
files and observe that there is little or no standardization of filing systems. In addition, according
to these studies, some of the Regions have not conducted an inventory of their .records.
Vital Records
A vital records/disaster recovery plan checklist is included in the handbook "Establishing
and Managing a Records Management Program" published by OSWER IMS, and the revised IRM
model discusses the life cycle approach to vital records by identifying specific functions to be
employed by the records center. The Superfund Doeument Management (SDM) Study asserts that
there is not a viable security program established for the Superfund records, and recommendations
are made for establishing a practical process to identify and handle essential" documents.
Public Access
One study discussed Regional limitations to responding to FOIA requests in terms of
staffing constraints. The study also noted the amount of time spent by staff responding to
requests. The Strategic Plan states that the need for sharing information with the public requires
re-examining some of the information services (e.g., records centers, dockets, etc.) that were
initially developed, managed, and funded primarily to serve internal needs; the Plan also suggests
that public access should be considered in the development of any new systems.
Staffing
Records management roles and responsibilities for various levels of Regional
management are outlined in the OSWER IMS handbook. The Revised IRM Model presents
records management staff functions in terms of the primary functions of the records management
program and associated personnel needs for the Regional program, noting primary variables to be
considered in the allocation of personnel. The SDM Study assembled data on the staffing costs
associated with existing filing, retrieval, copying, and distribution activities in the Regions. In the
field evaluation study of Region IV, the Region's practice of rotating a records center officer
through the program offices is supported. Regional records management staff and functions are
described and perceptions regarding available staffing resources are discussed in OIRM's
evaluation of Regional Superfund records management initiatives. Finally, the Strategic Plan
expresses a need and a commitment to attracting and retaining highly skilled IRM experts to
manage the Agency's increasing investments in advanced technology.
Space, Equipment and Materials
The OIRM evaluation of Regional Superfund records management initiatives provides
equipment descriptions and innovative methods for obtaining space in the program planning
stages. The SDM Study documents existing costs associated with floor space and off-site storage
in the Regions; a space planning checklist is offered in the OSWER IMS handbook. Equipment
needs and options for the system are presented in light of the support to be provided by'OIRM
under the new model. Information user services are outlined, such as the Regional Office
10 Applicable Guidance Report
-------
Summary of Documents
Information Center, and the Regional.Office Library. The Strategic Plan provides insight on the
review and scrutiny received from OMB during large and small procurements. The Plan also
discusses the development by OIRM of Agency-wide information architectures for program,
administrative, and scientific systems and hardware telecommunications'.
Records Center Structure and Functions
The SDM Study describes the problems inherent in most existing Regional central
facilities, including lack of file security and integrity, duplicating efforts, and dealing with diverse
file structures across program records series. The revised IRM model cites advancements of
certain Regions as examples of the implementation of centralized records centers.
Life Cycle Functions
The SDM Study briefly summarizes the current procedures in place both at Headquarters
and in the Regions for the creation, distribution, storage, and retrieval of Superfund records. A
field evaluation of Region IV suggests that the Region give careful consideration to its present
practice of utilizing contractors for all of its records management program needs; knowledge and
expertise of records management is not being developed among EPA managers. A similar study in
Region X reports various criticisms, including records schedules that are out of date, with
provisions of the EPA records schedule not being applied; duplication of information; and lack of
identification of essential records, or provision for their archiving. The Strategic Plan states an
objective of providing appropriate technical assistance and client support to facilitate efficient use of
resources to ensure effective and appropriate handling of Agency records,
Organizational Options
In the evaluation of Regional Superfund records management initiatives, options for
implementing the program are provided from several Regional records management perspectives.
Modifications to the initial structure are also provided to assist in anticipating issues related to
program organization and anticipated growth. The SDM Study proposes a preliminary project plan
with a high-level concept for the development of a Superfund Document Management System that
would drive the handling of all Superfund documents.
Technology Options
Several components of the IRM program's mission statement revolve around technology,
especially the need for EPA employees to make productive use of technology and the need for the
technology to be transparent to the users. The Strategic Plan cites some of the current work
environment, information technology, and legislative trends that impact the technological directions
of the Agency, such as advancements in image scanning and CD-ROM technology as well as
increased public access requirements. The revised IRM model introduces a range of systems for
integrating data throughout the records management program. The link between the Program
Systems Division and Regional offices is emphasized as an approach for ensuring technological
consistency. This issue also relates to cross-program information integration.
11 Applicable Guidance Report
-------
Summary of Documents
Cross-program Information Integration
The Region X records management evaluation is critical of the decentralized state of
records management functions in the Region whereby several branches have their own paid
records managers and are maintaining and disposing of files according to their own individual
schemes. The report calls for the formal establishment of a centralized records center that is
responsible for the handling of all Federal records and their transfer to a Federal Records Center.
In addition, in Region IV the report recommends that the Region develop a network of records
officers in each program and staff unit to act as a liaison and communication link.
Training
The evaluation of Superfund records management initiatives discusses personnel training
as a function of the pre-implementation planning for each section. Limitations to training are also
presented as a resource issue, where Headquarters support is needed to help address program
growth. The Region X evaluation report cites the need for better training in records management
for both clerical and program staff. The Strategic Plan states the IRM program's commitment to
enhancing productivity through the educated use of technology. To attain this goal, training
programs for IRM professional development, including technical training in records management
are considered to be critical. Additionally, training for the user community on technological topics,
such as the impact of image processing and the use of new technologies is a priority.
While the majority of the documents reviewed for this project contain legal and administrative
requirements for conducting records management, various studies and other resource materials,
which provided information on the practical application of these requirements, were also reviewed.
These documents either apply subjective analysis to existing programs, or provide element(s) of
the framework necessary to manage EPA's records.
12 Applicable Guidance Report
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IV. APPENDIX
1. U.S. Environmental Protection Agency, Office of Information Resources
Management, EPA Information Security Manual. December, 1989
2. U.S. EPA, Office of the Administrator and Office of Executive Support, Freedom
of Information Act Manual - 1550. 1986
3. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
Response. Establishing and Managing a Records Management Program. April 1989
4. U.S. Environmental Protection Agency, Office of Information Resources
Management, Information Resources Management Policy Manual (2100).
November 1987
5. U.S. Environmental Protection Agency, Office of Information Resources
Management, National Data Processing Division, IRM Strategic Plan: 1991 - 1995
(draft). May 1990
6. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
Response, Interim Guidance on Administrative Records for Selection of CERCLA
Response Actions (#9833.3A). March 1, 1989
7. U.S. Environmental Protection Agency, Office of Information Resources
Management, Records Management in the EPA: An Overview for Regional
Managers (Volume 1): Records Management Fundamentals (Volume 2). January 18
and 19, 1989
8. U.S. Environmental Protection Agency, Office of Administration and Resources
Management, Revised Information Resources Management Model. January 1989
9. Office of Information Resources Management, Environmental Protection Agency,
Study to Evaluate Regional Superfund Records Management Initiatives:
Final Regional Reports. October 20. 1988
Region VIII Baseline Summary. May 12, 1988
Preliminary Assessment Report. November 25. 1987
Regional Baseline Summaries. November 13, 1987
10. U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response and Office of Waste Programs Enforcement, Superfund Document
Management Study - Initiation Phase Report. December 6, 1989
11. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
Response. System Life Cycle Guidance - 9028. 1989
12. National Archives and Records Administration, Electronic Records Management:
Final Rule. May 8, 1990
13. National Archives and Records Administration, Evaluating a Vital Records
Program: A NARS Self-Inspection Guide for Federal Agencies. 1983.
13 Applicable Guidance Report
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Appendix
14. National Archives and Records Administration, Office of Records Management,
Evaluating Files Maintenance and Records Disposition Programs. 1988
15. National Archives and Records Administration, Federal Archives and Records
Centers. Chapter 13, "The Federal Vital Records Program," 1979
16. National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Audiovisual Records. 1990
17. National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Cartographic And Architectural Records.
1990
18. National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Electronic Records. 1990
19. National Archives and Records Administration, Micrographics: 36 CFR Pan 1230.
July 2, 1990
20. National Archives and Records Administration, Records Management Regulations:
Final Rules. July 2, 1990
21. National Archives and Records Administration, Vital Records During an
Emergency. 36 CFR Pan 1236, 1 July 1988.
22. Federal Records Center - Seattle, Agency Records Management Evaluation.
Environmental Protection Agency Region 10. June, 1990
23. Federal Records Center - Atlanta. Records Management Program Field Evaluation.
Environmental Protection Agency Region 4. April, 1990
24. U.S. General Services Administration, Information Resources Management
Services, Electronic Recordkeeping. July 1989
25. U.S. General Services Administration, Office of Information Resources
Management, Forms Management. 1985
26. U.S. General Services Administration and National Archives and Records Service,
Office of Federal Records Centers, Records Management Handbook: Disposition of
Federal Records. 1981
27. Reagan Administration, Executive Order 12656-Assignment of Emergency
Preparedness Responsibilities, 18 November 1988
14 Applicable Guidance Report
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TITLE:
U.S. Environmental Protection Agency, Office of Information Resources Management,
EPA Information Security Manual. December 1989
DOCUMENT OVERVIEW:
The Information Security Manuals are procedural manuals that explain to EPA
managers and staff how to comply with the security responsibilities that were developed
and articulated in the Agency's 1987 Information Security Policy. There are two manuals,
one that deals exclusively with PC security (volume 1) and the other (volume 2) that covers
all types of information assets (paper records, mainframes and minicomputers, information
systems, PCs, and word processors). Volume 2 is focused on in this review as it is the
most relevant to Regional records management The manual is divided into the following
sections:
General information
Information security roles and responsibilities
Minimal security controls for minicomputer/mainframe installations
Determining the need for additional controls
Personnel security and training
Security for minicomputer and mainframe installations
Security for personal computers and PC LANs
Security for word processors
Security for application system development, operations, and maintenance
Security for paper records.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This manual covers the procedural aspects of information security. Specifically,
this manual relates to regional records management in the following categories.
Security
EPA's Information Security Policy (contained in Appendix A of this manual)
establishes a comprehensive, Agency-wide security program to safeguard EPA's
information resources. The policy defines information and applications (or systems) as
either sensitive, such as Confidential Business Information, Privacy Act, or data critical to
performance of primary Agency missions, or as not sensitive and provides definitions of
each. The three main objectives of the program - information availability, integrity, and
confidentiality - are also discussed along with the information security problem itself.
Section 3 of this manual discusses minimum security controls that are required for
minicomputer/mainframe installations, PCs, PC LANS, and"word processors. Specifically
the section describes the security measures needed to ensure the basic physical and
environmental protection of ADP equipment and magnetic media. This section also
establishes administrative procedures which govern the use of computers and commercial
software. The measure described in this section can be implemented without first
performing a risk analysis.
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Section 4 of Volume 2 provides guidance on determining the need for additional
controls beyond those described in Section 3 through the provision of criteria by which the
sensitivity and the degree of sensitivity of each application or collection of information can
be evaluated.
Section 6 of Volume 2 sets forth security procedures for minicomputer and
mainframe installations, Section 7 for PCs, and Section 8 for word processors (i.e.,
Lexitrons). Section 9 deals with security issues and concerns throughout the software life
cycle (from development to operatioirto modification). Security measures for paper and
microform records are discussed in Section 10. The focus of this section is on significant
quantities of records that constitute manual information systems, rather than normal desk or
office files. This section also provides information on other procedures governing
sensitive information to which paper and microform records must comply (e.g., the Office
of Solid Waste and Emergency Response has issued procedures concerning RCRA
Confidential Business Information). Each of these sections deals with security procedures
through examining threats to the particular system in question and through providing
information on procedures to maintain availability, integrity, and to preserve
confidentiality.
Public Access
Public access is discussed implicitly due to the need to monitor security of records.
Staffing
This manual devotes a chapter to information security roles and responsibilities.
Guidance on information security roles is given through the provision of a framework for
assigning security responsibilities. The focal point of this framework is the SIRMO.
Chapter 2 then provides guidance on assigning responsibilities to the previously defined
roles. These responsibilities center around three different management control processes
which are described in this manual.
Section 5 provides guidance on screening and clearance required for persons
involved in the design, development, maintenance, and operation of sensitive automated
systems and facilities. The section also offers guidance on separation of security duties and
the procedures which should be followed.if an employee is terminated or laid off.
Space, Equipment and Materials
This manual discusses the appropriate environmental conditions for equipment and
magnetic media to ensure that security is maintained.
Organizational Options
The Information Security Policy that is provided in Appendix A of this manual
identifies offices within EPA that need to be involved with security issues and lists specific
responsibilities for each office.
Training
Section 5 states that the Office of Administration and Resources Management is
coordinating the development of information security training programs for the Agency.
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TITLE:
U.S. Environmental Protection Agency, Office of the Administrator and Office of
Executive Support, Freedom of Information Act Manual - 1550. 1986
DOCUMENT OVERVIEW:
This manual provides guidance on policy and procedures for implementing EPA's"
Freedom of Information Act (FOLA)/Public Information Regulations (Title 40 CFR,
Chapter 1, Pan 2). The Freedom of Information Act is found at 5 U.S.C. 552.
In general, an office has four options in handling a FOIA request for existing,
located records. These options may be applied singly or in combination for a given
request. The options are based on the application of nine categories of exemptions. The
options arc: releasing documents; withholding documents that fall under one of the nine
exemption categories; partial withholding of documents that contain both exempt and non-
exempt information and necessary deletions can be made without making the document
unintelligible; and'discretionary release of documents under certain exemption categones if
no important Agency purpose is served by withholding.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
File Inventory/Structure
At minimum, in order to assist the public and comply with the law, the manual
identifies a legal requirement for the Regions to be able to locate records requested by the
public.
Public Access
In complying with FOIA regulations, the Regional offices must provide for the
handling of such requests for public information. This manual documents the policies that
must be followed to determine what may be released, what fees may be assessed, and what
procedures must be followed to track and file the request.
Records Center Structure and Functions
The manual further provides guidance on logging, routing and file-keeping of
requests', assessing of fees, appeals, roles and responsibilities of Agency staff, and sample
letters and forms.
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TITLE
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Establishing and Managing a Records Management Program. April 1989 •
DOCUMENT OVERVIEW:
This brochure provides practical information for program managers and staff on
records management, and suggests a framework of issues to be considered to establish a
records management program. The program approach serves to define goals and
objectives, commit resources, and maintain operations. This document identifies the
primary records management activities as:
• Organizing records according to uniform classification systems and
indexing them
Establishing circulation control procedures
Converting records to appropriate storage media
Identifying vital records
Establishing special procedures for handling sensitive information
Establishing records retention schedules.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This document provides a framework for approaching the management of records
in the Regional office; it is not a procedural manual.
File Inventory/Structure
An inventory checklist is included in the appendix to this brochure. A file
structure/indexing checklist is also included.
Vital Records
Defining and making provision for vital records are functions identified in the systems life
cycle development stage. A vital records/disaster recovery plan checklist is included as an
attachment to the document.
Staffing
The brochure outlines possible records management roles and responsibilities for
various levels of management.
Space, Equipment and Materials
Resource needs may be very dependent on the individual Records Systems
developed. A space planning checklist is included,
Life Cycle Functions
A summary explanation of the activities conducted in the systems life cycle is given.
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TITLE:
U.S. Environmental Protection Agency, Office of Information Resources Management,
Information Resources Management Policy Manual (21001. November 1987
DOCUMENT OVERVIEW:
This manual establishes a policy framework for the Information Resources Management
(IRM) program. Information Resources Management means planning, budgeting, organizing,
directing, training and controlling information. If encompasses both information itself and
related resources such as personnel, equipment, funds and technology.
The manual is intended to provide EPA with a structure for the implementation of the
Brooks Act of 1965, the Paperwork Reduction Act of 1980, the Privacy Act of 1974, the
Freedom of Information Act of 1966, as amended in 1974 and 1986, and policies and regulations
issued by OMB and GSA.'
The Paperwork Reduction Act of 1980 introduced Information Resources Management to
the Federal Government, emphasizing information as a resource with associated costs and
values. Concepts advanced by the Act through the IRM approach include the life cycle
management of information activities (creation, collection, and use); information functions
(automatic data processing, records management, reports management, and telecommunications);
and the integrated approach to managing information resources (the total systems concept).
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
The policies defined in this manual proscribe- the-frarnewortrunder which the Regions must
manage the information resources under their direction. While the specific procedures for
implementing these policies are not outlined, as those procedures are developed they must adhere
to these guidelines.
File Inventory/Structure
This guidance addresses the Agency's responsibilities under the Paperwork Reduction
Act to develop and maintain an inventory of its information systems and periodically review its
information management activities.
Staffing
This guidance discusses the need to, under the Paperwork Reduction Act, assign to a
designated senior official the responsibility for the conduct of and accountability for acquisitions.
Life Cycle Functions
This manual provides guidance on Agency controls related to basic management functions
of planning, budgeting, acquisition, data management and evaluation of IRM activities; data
standards to provide consistent definition of data and to facilitate cross-media use of data; ADP
resources management; selection, installation, use, maintenance, and administration of voice
communications; security program to safeguard Agency information resources; objectives,
responsibilities, and procedures for collecting information fro the public; objectives,
responsibilities and procedures for records/information management program (further detailed in
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the EPA Records Management Manual); Agency principles for protecting the privacy of
individuals; principles that govern the operation of the EPA library network.
Cross-Program Information Integration
This guidance discusses the need to ensure that EPA's information systems do not
overlap with each other or duplicate the systems of other agencies.
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TITLE:
U.S. Environmental Protection Agency, Office of Information Resources Management,
National Data Processing Division, IRM Strategic Plan: 1991 - 1995 (draff). May 1990
DOCUMENT OVERVIEW:
The draft Information Resources Management (IRM) Strategic Plan defines the
mission of EPA's IRM Program through 1995 and specifies the accomplishments,
investment areas, resource needs, and responsibilities required to achieve this mission.
This Strategic Plan serves as a component of the Office of Administration and Resources
Management's strategic plan and fulfills the Federal requirement for annually updated
mission-based ERM plans. The Strategic Plan is organized into six sections, including:
• Mission statement
Externalities analysis
Strengths, weaknesses, opportunities, and threats analysis
Strategic issues
Goals and objectives
• Strategic directions.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
The IRM Strategic Plan provides a framework within which regional records
management over the next five years can be considered. The Plan identifies priorities and
objectives within EPA's IRM Program which can then be applied to regional records
management Specifically, the Strategic Plan provides direction in the following areas:
Budget Formulation/Constraints
The IRM Strategic Plan provides priorities and goals within the IRM arena and
identifies some funds (e.g., grant funds) that are available to support attainment of the
long-range IRM goals.
Public Access
The public's increasing concerns for and involvement in environmental issues and
the resulting impacts on EPA is one of the main themes in the Strategic Plan. The Strategic
Plan states that the need for sharing information with the public requires reexamining some
of the information services (e.g., records centers, dockets, etc.) that were initially
developed, managed, and funded primarily to serve internal needs as well as considering
public access in the development of any new systems.
Staffing
The Strategic Plan expresses a need and a commitment to attracting and retaining
highly skilled IRM experts to manage the Agency's increasing investments in advanced
technology. This commitment extends to the need to promote professional development
within the IRM arena.
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Space, Equipment and Materials
The Strategic Plan provides information on the review and scrutiny received from
OMB during large and small procurements. The Plan also discusses the development by
OIRM of Agency-wide information architectures for program, administrative, and scientific
systems and hardware/telecommunications, including Information Strategy Plans, priority
acquisitions, and maintenance information.
Life Cycle Functions
The Strategic Plan defines the provision of quality service and leadership in the
information area as an IRM goal. Components of this goal include ensuring effective and
appropriate handling of Agency records through:
• Developing standards and guidelines for records management
• Reviewing and improving Agency records management practices.
OIRM/NDPD also has an objective of providing appropriate technical assistance and client
support to facilitate efficient use of resources. This objective will be met through providing
assistance in system design, development, and operation matters.
Technology Options
Several components of the IRM Program's mission statement revolve around
technology, especially the need for EPA employees to make productive use of technology
and the need for the technology to be transparent to the users. The Plan cites some of the
current work environment, information technology, and legislative trends which impact the
technological directions of the Agency, such as advancements in image scanning and CD-
ROM technology as well as increased public access requirements.
The Strategic Plan discusses some of the potential benefits of technological
additions but stresses the need to weigh any benefits against .the cost of new investments
and potential disruptions. For instance, the Strategic Plan emphasizes the need in the
records management area to ensure that automated records management solutions are both
cost effective and capable of meeting handling and access requirements. To provide further
guidance in this area, the IRM Program is assessing the Agency's technology needs and the
capabilities of specific technologies, and then will be procuring the most appropriate
technologies and capabilities to meet Agency-wide needs. Priority procurements are listed
in the Strategic Plan.
Cross-Program Information Integration
One key component of IRM's strategic vision is the need for integrated
environmental information managed as a corporate resource so that it is readily accessible
and in usable form. The Strategic Plan envisions the development of data integration tools
and activities to complete this vision, including establishing a data administration program,
which provides standards to promote sharing information, and incorporating integration
tools and activities into EPA Regional offices. Additionally, the Plan expresses a
commitment to developing policies that facilitate integrated information programs and
developing and managing networks, such as records centers, for effective cross-program
access and sharing.
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Training
The Strategic Plan states the IRM Program's commitment to enhancing productivity
through the educated use of technology. To attain this goal, training programs for IRM
professional development, including technical training in records management, are
-considered to be critical. Additionally, training for the user communiry on technological
topics, such as the impact of image processing and the use of new technologies is a
priority.
10
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TITLE:
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Interim Guidance on Administrative Records for Selection of CERCLA Response Actions
f#9833.3A^. March 1, 1989.
DOCUMENT OVERVIEW:
This guidance addresses the establishment of Administrative Records under §113 of
CERCLA. The administrative record serves two primary purposes:
First, the basis for the response selection is set forth in the record, and under §113(j),
judicial review of any issue concerning the adequacy of a response selection is limited to the
record. Second, '§113(k) .requires that the administrative record act as a vehicle for public
participation in the selection of the response action.
This guidance document discusses the involvement of parties outside the agency,
discusses procedures for compiling and-maintaining the records, and examines the types of
documents that should be included to ensure that the Agency's administrative records meet the
stated purposes. If the record is incomplete or fails to provide an adequate explanation of the
basis for the Agency's response action selection, the court may remand the case to the Agency for
reconsideration of its decision.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
Since Superfund records comprise a majority of the volume of Regional records, the
compilation of the administrative record, and the records management functions that support that
function, may strongly influence the overall Regional records management procedures. This
document addresses:
File Inventory/Structure
The core of this document provides detailed guidelines on the specific information
that must be included in, and that which may excluded from, the administrative record.
Security
Document room security procedures are outlined for maintaining the integrity of the
record files, both in the Regional office and at the site.
Public Access
Different procedures are outlined for removal and remedial response actions for
publishing a notice of availability, and for making the record available for public inspection
in the vicinity of the site; logging and copying activities for public inspection are detailed.
Staffing
The guidance identifies key personnel who will be involved and oversee the compilation
of the administrative record and establishes roles and responsibilities of the Administrative
Record Coordinator, including the coordination responsibilities with other Regional staff.
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Life Cycle Functions
Recommended location of the record is specified, as is a recommended structure for
indexing the specified documents.
Technology Options
The Office of Information Resources Management has granted approval for the
administrative record file to be maintained in microform.
12
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TITLE:
U.S. Environmental Protection Agency, Office of Information Resources Management,
Records Management in the EPA: An Overview for Regional Managers ("Volume IV
Records'Management Fundamentals (Volume 2). January 18 and 19, 1989
DOCUMENT OVERVIEW:
The Records Management in the EPA volumes are intended to clarify EPA's basic
records management goals and definitions, to explain the records management life cycle,
and to provide instructions for the proper handling of records and for completing the main
records management forms. The rwo volumes present much of the same information but
were prepared for different audiences - Regional Managers (Volume 1) and those
individuals who deal with records on a day-to-day, more operational basis (Volume 2).
The volumes are organized into the following sections:
• Seminar slides
Volume 1 - definitions and an overview of records management
goals and the life cycle are provided
Volume 2 - definitions and an overview of records management
goals are provided as well as objectives and responsibilities for each
stage of the records management life cycle
• Policy/official records (both volumes)
• Disposition schedule (both volumes)
Records Management Manual (both volumes)
Objectives and responsibilities
Reporting requirements
Disposition of records
Vital records
Filing equipment and supplies
Micrographic management
Files maintenance
Electronic records
• Advanced records management technology (Volume 1)
Relevant EPA forms and instructions (Volume 2)
. Records management references (both volumes).
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
These volumes cover many procedural aspects relevant to records management in
the regions, particularly in the Records Management Manual contained in both volumes, as
well as provide an overview of records management goals and objectives.
Vital Records
Chapter 4 of the Records Management Manual defines vital records and the purpose
of the Vital Records Program. This purpose involves protecting EPA's
records/information that are necessary for the Agency to continue its key functions and
activities in case of an emergency. This chapter delineates the responsibilities of the key
personnel in the Vital Records Program, including the EPA Emergency Preparedness
Coordinator, the EPA Records Management Officer, Senior Agency Managers, and Vital
13
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Records Officers. Procedures for transferring vital records to and retrieving these records
from the alternate site are given.
Public Access
Public access is listed in the overview slides as one of the unique requirements for
EPA records. The need to protect sensitive, proprietary, and other types of information is
also discussed.
Staffing
The Records Management Manual lists specific responsibilities of staff members in
each of its subsections, i.e., vital records, disposition, electronic records, etc.
Space, Equipment and Materials
The Records Management Manual prescribes criteria, a checklist, and procedures
for the acquisition of filing equipment and supplies.
Life Cycle Functions
The overview section of these volumes defines the records management life cycle
and categorizes each phase as either active or inactive. In Volume 2, specific objectives and
general responsibilities for day-to-day records management in each phase of the life cycle
are given.
Chapter 7 of the Records Management Manual covers files maintenance. This
chapter provides procedures for file stations, where the Agency's official records are filed,
and for the files custodian who is responsible for the operation of the files station. These
procedures are intended to ensure the integrity of all official records and to keep
information relating to a subject in one location. Specifically, guidance is given on the
preparation and classification of file material and the maintenance of files. A sample Files
Maintenance Plan is also provided.
Records disposition is covered in detail in the volumes, including reference to 18
U.S. Code 2071, which describes penalties for misuse or management of records, and
definitions of official records, extra reference copies (non-record material), and personal
papers. The Records Management Manual describes EPA's policy with regard to records
disposition, including its goals of not maintaining inactive records in costly office space,
releasing filing equipment for reuse, and protecting important records. The Manual also
lists criteria and procedures for rearing and retrieving records. Additionally, guidelines for
the protection of retired records, especially those subject to the Privacy Act or containing
confidential business information are given. A copy of the records control schedule (last
revised in 1986) is provided in the volumes. This schedule details retention and disposition
requirements for program-specific records as well as items common to all offices, including
schedules of daily activities files dealing with the Privacy Act, FOLA, and office
administrative files.
Chapter 6 of the Records Management Manual discusses micrographic management
for records, excluding the use of Computer Output Microfilm and other ADP hardware.
The chapter provides definitions relevant to micrographics, offers procedures for
maintaining and protecting permanent microform records, and discusses the need to
develop a new records control schedule for disposition of microform records (even if the
14
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paper records are already scheduled). Standards are provided for film tests, inspections (to
ensure that standards are met), and reviews of micrographic systems.
Chapter 8 offers guidelines on the documentation and preservation of records
created, stored, or transmitted using electronic means, including personal computers, word
processors, or other electronic office equipment- AAtirinoaUy-, electronic records
responsibilities~fbr EPA staff members are given.
Volume 2 contains copies of relevant EPA, National Archives and Records
Administration, and standard forms as well as instructions for completing each form.
These forms are linked to the relevant stage of the records management life cycle.
Organizational Options
The Records Management Manual states the objectives of the records management
program and lists the records management responsibilities of various organizations within
EPA.
Technology Options
The overview slides in the first section of each volume provide general information
on the role of technology in records management, the types of technologies relevant for use
in records management, and some of the characteristics of each technology.
Chapter 6 then provides extensive information on justifying the need for a
micrographic system, including criteria and format for written feasibility studies, as well as
the review process for proposed acquisitions, and procedures for the purchase/lease of
microfilm equipment or services.
A section of Volume 1 is devoted to articles on advanced records management
technology, including optical disk, computer-assisted retrieval systems, and image
management systems.
15
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TITLE:
U.S. Environmental Protection Agency, Office of Administration and Resources
Management, Revised Information Resources Management Model. January 1989
DOCUMENT OVERVIEW:
The Revised Information Resources Management Model was designed to amend the
mission of the Office of Information and Resources Management (OIRM) to include the
records management function. This change in mission is precipitated by the increase in
records management initiatives and the lack of coordination of Regional records
management systems. The revised model is intended to facilitate consistency, use the
Regional IRM Managers network to provide an effective medium for information exchange
and technology transfer, and provide management support and technical direction for the
Regional records management functions.
The contents of-the revised model are as follows:
Overall IRM Branch and Section Management
Central ADP Operations and Support
Software Development and Management
Information User Services
Records Management Support
Voice, Image, and Data Telecommunication and Networking.
The original model, entitled Regional Office IRM Organizational Model and Resource
Profiles, March 1987, is provided as an attachment.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
Vital Records
Life cycle approach is discussed in terms of the high growth rate of the Superfund
program. Functions to be employed by the records center to ensure the integrity of the files
throughout records control are also identified.
Staffing
Records management staff functions arc presented in terms of the primary functions
of the records management program and the associated personnel needs for the Regional
program. The document notes the primary variables to be considered in the allocation of
personnel, including the size of the Region, number of NPL sites, current state of records
management, future plans, and office moves.
Space, Equipment and Materials
Equipment needs and options for the system are presented in light of the support to
be provided by GERM under the new model. Information user services are outlined, such
as the Regional Office Information Center, and the Regional Office Library.
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Records Center Structure and Functions
The advancements of certain Regions are cited as examples of the implementation of
centralized records centers.
Technology Options
A range of systems for integrating data throughout the records management
program are introduced. The link between the Program Systems Division and Regional
offices is emphasized as an approach for ensuring technological consistency.
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TITLE:
U.S. Environmental Protection Agency, Office of Information Resources Management,
Environmental Protection Agency, Study to Evaluate Regional Superfund Records
Management Initiatives:
Final Regional Reports. October 20. 1988
Region VITI Baseline Summary. May 12, 1988
Preliminary Assessment Report. November 25, 1987
Regional Baseline Summaries. November 13, 1987
DOCUMENT OVERVIEW:
In an effort to promote coordination of further efforts in managing Superfund
records and to disseminate effective records management techniques, OIRM documented
the success of Regional records management initiatives to improve Superfund
documentation. The study was conducted in two phases.' In the first phase, conducted in
November 1987, OIRM reviewed Regions I, III, VI, and VII, to provide a baseline for
measuring Regional progress in terms of the management of records required to support the
growing Superfund program requirements. In May 1988, Region VIE was added to the
review as part of the first phase. The second phase, undertaken in August and September
1988, was a series of follow-up reviews to document the further success of the Regional
records management programs since the initial visit
In phase one. Regions were assessed according to their records management needs,
resources available, current and anticipated resource needs, and the Region's records
management progress to date. For each Region, the discussion is presented according to
the data collection areas employed in the study methodology:
Project Initiation
Pre Implementation Planning
Objectives
Implementation
Resources
Monitoring Efforts and Modification
Benefits/Costs/Problems
Outlook.
Exhibits oudining the scope of the Regional initiatives and estimating records growth and
records management resources are included in the document. Additionally, summary
charts providing a comparison of records management data for all Regions are included as
an attachment.
V
Following the compilation of the baseline summaries, a Preliminary Assessment
was prepared, to present the evaluation of the four Regional initiatives. This report
presents findings and assesses the implications of those findings as they related to each
Region's records management program. As a second pan of the Agency's review of
Regional Superfund records management initiatives, OIRM conducted telephone interviews
of all ten Regions to assess overall program accomplishments and resource needs.
Based on the telephone survey and findings presented in the preliminary
assessment,, the scope of the baseline.summaries was expanded to document the success of
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Region VOTs records management initiative to improve the maintenance of Superfund
documentation. The Region VIE report is presented in the same format as the initial
baseline summaries. •
As the second phase of the OIRM evaluation. Final Regional Reports were prepared
to document the success over the last six to ten months of four Regional records
management initiatives to improve Superfund records documentation. This report provides
a Region-by -Region overview of progress toward records management objectives for
Superfund records and also assesses the changes in objectives since the initial visit
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
Budget Formulation/Constraints
The summaries present discussions of budget formulation as it relates to the
implementation and pre-implementation planning for the Superfund records management
program. Funding sources and options used by the Regions are presented.
Resource constraints as perceived by the Regions, are presented in the findings for
each Regional review. Budget constraints are also discussed in the outlook for the
program, as OIRM looked ahead to determine how to meet anticipated needs.
File Inventory/Structure
File inventory is presented in terms of the features of some of the Regional
programs, such as that for Regions I and II.
Public Access
The limitations for responding to FOIA requests are discussed in terms of staffing
constraints. The amount of staff time spent for Regional responses to requests is also
noted.
Staffing
Regional perceptions regarding available resources are discussed in terms of the
staffing capabilities for the program. Regional records management staff and functions are
described.
Space, Equipment and Materials
Because the space allocations for the Regions vary considerably and because of the
need for space to accommodate the expanding Superfund program records, this topic is
often covered in the discussion of resource constraints, as well as in the implementation
and outlook sections of the reports. Equipment descriptions and innovative methods for
obtaining space in the program planning stages arc presented in the Regional discussions.
Records Center Structure and Functions
The design and planning of records centers is described in terms of innovative use
of staffing, such as shared staffing with other programs or Agency areas.
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Organizational Options
The options for implementing the program are provided from several Regional
records management perspectives. Modifications to the initial structure are also provided to
assist in anticipating issues related to program organization and anticipated growth.
Technology Options
Technology options are presented in terms of storage media, such as
micrographics, being explored in some Regions. Technology is cited particularly as an
area for additional Headquarters support to help Regions deal with anticipated growth in
Superfund records.
Cross-Program Information Integration
The primary focus of this analysis was Superfund records, although some
information is applicable to other programs.
Training
Personnel training is discussed as a function of the pre-implementation planning
section for each section. Limitations to training is also presented as a resource issue, where
Headquarters support is needed to help address program growth.
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TITLE:
U.S. Environmental Protection Agency, Office of Emergency and Remedial Response and
Office of Waste Programs Enforcement, Superfund Document Management Study -
Initiation Phase Report. December 6, 1989
DOCUMENT OVERVIEW:
This report summarizes the findings of a study conducted jointly by OERR and
OWPE to first develop an understanding of the current Superfund document management
environment, in order to quantify the costs and risks associated with current practices and
propose long term solutions for improving the efficiency of document handling; secondly,
to identify cost-effective interim improvements and provide management with
recommendations for improving guidance on document management and records handling
procedures.
The study was limited to documentation supporting pre-remedial, remedial, -
removal, and enforcement actions, including financial, technical, enforcement and some
laboratory records. Source data was gathered through individual interviews, working
group meetings, and surveys of site files.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
File Inventory/Structure
The study characterizes the inventory of Superfund records with regard to content,
size, location, and users.
Security/Vital Records
The study asserts that there is not a viable security program established for the
Superfund records at the Regional or Headquarters level. Recommendations arc made for
establishing a process to identify and handle essential documents.
Public Access
t
The study points to a general Region-wide lack of a mechanism and subsequent
lack of follow-through to FOIA requests.
Starring
The study assembled data on the staffing costs associated with existing filing,
retrieval, copying, and distribution activities. These data are also portrayed in extensive
graphics.
Space, Equipment and Materials
Costs associated with floor space, off-site storage, and contractors arc identified
and portrayed in detailed graphics.
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Records Center Structure and Functions
The study describes the problems inherent in most existing central facilities,
including file security and integrity, duplicating and diverse file structures across program
series.
Life Cycle Functions
The study summarizes the current procedures in place both at Headquarters and in
the Regions for creation, distribution, storage, and retrieval of Superfund records.
Recommendations are made to develop comprehensive and consistent guidelines for
document handling policies and procedures.
Organizational Options
The study proposes a preliminary project plan with a high-level concept for the
development of a Superfund Document Management System that would drive the handling
of all Superfund documents.
Technology Options
A program-wide system solution for managing Superfund documents,
incorporating a multi-media approach including paper, micrographics, and image-based
storage and retrieval technologies is recommended. At a minimum, the study suggests
integration of CERCLIS, RPMS, and WasteLAN data bases
22
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TITLE:
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
System Life Cvcle Guidance - 9028. 1989
DOCUMENT OVERVIEW:
The guidance is presented in three sections: Overview of the document; a description of the
nine stages of the system life cycle, with specific documentation requirements for each step; and
practice papers that provide examples of various aspects of a life cycle project
Every information management system that supports the Agency's hazardous waste
program must comply with this directive. AU projects that follow this directive will also satisfy
the requirements outlined in OIRM's EPA System Design and Development.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
These guidelines are extensive in detail, but are particularly appropriate for any Region that
identifies a need to establish a comprehensive integrated system to handle a series of records. All
records management program elements identified as for this project that address the organizing,
tracking and maintaining of records access arc addressed in this guidance. This guidance does
not address the broader program issues of organizational options, budget constraints, public
access, or cross program information integration.
Life Cycle Functions
The guidance is instructive with regard to the administrative requirements involved in the
system life cycle process. Specifically, the guidance informs that the stages of the life cycle may
be altered to better suit a given project as long as the changes are documented in the Project
Management Plan that is developed during the corresponding stage of the life cycle, and are
reviewed and approved to ensure appropriate program management oversight Projects may
move forward while waiting for approval of the previous stage, with the exception of the
implementation stage. Approval must be obtained before implementation can begin.
Also, the guidance indicates that each procedure that is followed and decision that is made
within the system life cycle must be documented. Appendix 5 lists the documentation required
by this guidance, the stages in which it is to be created, and the stages in which it is to be
reviewed and revised. Additional appendices provide copies of suggested outlines for each of the
documents described.
The focus of the guidance is a detailed discussion of the systems life cycle in terms of the
objectives, decisions, activities and resulting products (documentation) of each of the nine stages:
• Initiation - This stage identifies the information management problem and the
environment within which it exists. A decision is made at the end of this stage
whether or not to commit resources to exploration of possible solutions to the
problem. The system is not necessarily assumed to be a new system or an
automated system. Alternatives will be discussed in the Concept stage.
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• Concept - During this stage alternative system concepts arc developed and analyzed,
and a final system approach is chosen. This stage provides the framework for the
remainder of the project. The concept developed here, however, may be refined as
the project progresses and new requirements are identified.
• Definition - During this stage the functional and data requirements identified in the
Concept stage are defined in greater detail, providing the opportunity for a more
extensive evaluation and definition of the selected system concept
• Design - During this stage the exact specifications of the concept are completed
based on the functional and data requirements identified in the Definition stage, and
a design for the complete system is developed.
Development - During this stage the concept becomes a working system as the
necessary hardware and software arc acquired, and all of the elements are
integrated. Tne elements of the system, including the data, should be ready for
implementation at the end of this stage.
Implementation - During this stage the system is installed at the user location and
tested to ensure that it is operating according to its specifications. Training of the
users is provided.
Production - During this stage the system is fully operational and should be
operated by the intended users. The system is used to solve the information
problem originally identified, and modifications are made when necessary.
• Evaluation - During this stage the system is reviewed to determine if it operates
efficiently and effectively addresses the information management problem. This
stage may be repeated several times during the system's life.
^ Archive - This is the final stage of the system's life cycle. It ensures orderly
termination of the system and the preservation of vital materials that may be needed
after the system is shut down.
The Appendices to these chapters contain a summary of objectives, decisions, activities, and
products for the particular stages as they are presented in the guidance.
This guidance includes a chapter titled "Crosscurting Considerations" that discusses, from a
life cycle perspective, topics that have significance in several of the stages of the system life
cycle.
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TITLE:
National Archives and Records Administration, Electronic Records Management: Final
Rule, May 8, 1990
DOCUMENT OVERVIEW:
This final rule, which became effective onJune 7, 1990, revises NARA regulations
for Federal agencies' electronic records. This rule defines electronic records and provides
procedures for managing electronic records, selecting and maintaining electronic storage
media, and meeting the legal requirements for the disposition of such records. The
Electronic Records Management rule is geared primarily toward the Agency's records
management staff as well as individual records systems managers. The rule, which was
published in the Federal Register, is divided into two main sections - one that deals with the
program requirements 2nd another that establishes standards for the use, creation,
preservation, and disposition of electronic records. An identical rule issued by the General
Services Administration was published along with the NARA rule.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This NARA rule is extremely applicable to Regional records management,
especially as the Regions are increasingly considering electronic media as alternatives to
paper for records systems. In this rule, the head of each Agency is required to ensure that
electronic records management is integrated with other records and information resources
management programs of the Agency. More specific guidelines and standards for
—e4eetronic records system are established in this rule in the following categorie"sT
Security
Requirements are given for electronic records security, including restricted access
as well as backup and recovery mechanisms.
Public Access
This rule addresses public access in terms of the need to maintain controls over-
classified, proprietary, and Privacy Act information stored electronically.
Life Cycle Functions
In this rule, NARA functional requirements for electronic records are given in the
following areas.
• Procedures for the creation and use of data files in electronic format,
including technical documentation and disposition instructions.
• Requirements for the creation and use of text documents in electronic
format, including identification, indexing and retrieval methods, security,
disposition, and standard interchange formats between various agency
systems.
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• Procedures for the judicial use of records, such as mandates for
standardized processes (generation and storage), retrieval approaches,
security mechanisms, and identification and disposition procedures.
• Standards for the retention and the destraction of electronic records.
Technology Options
This rule states that Federal agencies should define their requirements, based upon
an agency's individual records management needs, for selecting appropriate electronic
media and systems for storing agency records throughout the life cycle or for converting
from one storage medium to another.
Cross-Program Information Integration
This rule states that standard interchange formats between various agency systems
should be developed.
Training
This rule discusses the requirement to train appropriate agency personnel to
safeguard sensitive or classified records. Training also must be provided for users in the
operation, care, and handling of the equipment, software, and media used in a system.
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TITLE:
National Archives 'and Records Administration, Evaluating a Vital Records Program:
NARS Self-Inspection Guide for Federal Agencies. 1983
DOCUMENT OVERVIEW:
The purpose of this self-inspection guide is to assist Federal agencies in evaluating
their vital records programs to ensure compliance with the legal requirements as set forth in
FPMR 101-11.7. This guide is a series of questions which can be answered with a yes or
no. A no response is intended to highlight a potential deficiency in the program which
needs to be addressed. The guide is divided into the following sections:
• Planning, establishing, and staffing the program
• Evaluating potential hazards
Identifying vital records
Selecting protection methods
Choosing a storage facility
• ' Establishing operating procedures
• Promoting the program
• Reviewing the program.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
These self-inspection guide allows records managers to evaluate their own vital
records programs to determine if they are meeting the necessary legal requirements.
Specifically, this guide addresses the following areas:
Vital Records
Section 2 of the guide is intended to help an agency identify potential threats to vital
records, such as fire, water, etc. This section also provides questions that consider factors
which should be considered relative to these hazards.
Section 3's questions are intended to evaluate the identification process of a vital
records program. Section 4 focuses on the selection of protection methods, such as
duplicates, and Section 5 deals with the process of choosing a storage facility.
Section 6 is concerned with the operating procedures that are established for vital
records programs. These procedures include inventories, indexing, labeling, transfer to
storage, and other issues. Sample forms and instructions are also provided in this section.
The questions in Section 7 focus on promoting the vital records program within an
agency. Section 8 provides guidance on factors which should be taken in to.consideration
when conducting a review of the vital records program.
Staffing
Section 1 of this guide also provides questions on staffing issues associated with a
vital records program.
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Organizational Options
The first section of this guide poses questions on both the planning and the actual
establishment of a vital records program.
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TITLE:
National Archives and Records Administration, Office of Records Management, Evaluating
Files Maintenance and Records Disposition Programs. 1988
DOCUMENT OVERVIEW:
This guide was developed by the National Archives and Records Administration
(NARA) to help Federal agencies evaluate their files maintenance and records disposition
programs. These programs are required by Federal law (44 USC chapters, 29, 31, and 33)
and the same law requires the National Archives to provide regulations and guidance for
agencies. The regulations are found in 36 CFR Chapter XII. Guidance is provided
through.a variety of formal and informal mechanisms, including NARA bulletins, training
classes, informal assistance, and publications, such as this guide.
The format of this guide is a series of questions that can be answered with a simple
"yes" or "no." A "no" answer to a question indicates a possible problem that may require
corrective action to improve an agency's files maintenance and records disposition •
program.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This guide provides Regional records management staff with an excellent source for
monitoring the compliance of their records management programs with Federal
requirements. The questions in the guide are easy to follow and can serve as a step-by-step
jjuide to the proper administration of records management activity.
File Inventory/Structure
Parts n and HI of the guide contain questions that will help records management
personnel in evaluating their tiles maintenance programs. Following this questionnaire will
assist in the development and maintenance of an effective filing system that promotes the
prompt retrieval of needed documents and information. The questions in parts n and HI
will also help Regional records managers save costly storage space through eliminating
unneeded non-record material using appropriate filing equipment and supplies.
Staffing
The guide is designed so that sections can be extracted, copied and distributed to
appropriate agency personnel. For example: pans I, II, and IV may be answered by the
records manager or chief records officer, part II may be answered by each file station (or
office) supervisor, and part V may be answered by the records manager or, for large
agencies, by each records management staff or liaison individual who performs these
functions.
Life Cycle Functions
Part I of the guide, "General Program Requirements For Files Maintenance And
Records Disposition Programs", is comprised of groups of questions which cover the basic
elements of files maintenance and disposition programs as required by Federal Law (44
USC chapters, 29, 31, and 33). Answering these questions with respect to programs in-
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place in the Regions will allow records management personnel to assess the compliance of
their management programs with Federal requirements.
Parts IV and V of the guide assist records management personnel in gauging the
overall effectiveness of their records disposition programs and practices. The questions
seek to ensure the application of general management policies and specific programmatic
elements as required by Federal law.
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TITLE:
National Archives and Records Administration, Federal .Archives and Records Centers.
Chapter 13, "The Federal Vital Records Program," 1979
DOCUMENT OVERVIEW:
This document is a chapter in a Records Management handbook developed by
NARA. The intent of this chapter is to ensure that Federal agencies are administering a
vital records program so as to protect those records necessary to ensure the continuity of
essential Government activities during and following a national emergency. This handbook
is aimed at records managers who implement vital records programs in their agencies and is
divided into the following sections:
Definitions
Identifying vital records
• Providing copies of vital records
Storing vital records
Maintaining an effective program.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This chapter of NARA's records management handbook outlines requirements for
Federal agencies' vital records programs.
Vital Records
This chapter provides definitions of the two main types of vital records and lists the
three categories that Government department and agencies fall into with regard to vital
records. The chapter also specifics utility and cost as the two key criteria around which a
vital records program should be planned.
Chapter 13 then turns to the requirements for identifying vital records to ensure that
those records essential to the conduct of emergency functions and those that preserve the
rights and interests of individual citizens and the Government are selected. The chapter
specifies three types of functions which must be considered in this process - mission-
oriented, emergency-oriented, and emergency plan of operations. The chapter then
provides guidance on conducting a survey to identify vital records, including lists of the
types of vital records most common in the Federal government.
Further guidance is provided on the maintenance of vital records through a
discussion of the four main methods:
• Use of existing duplicates at other locations
• Creation of duplicates for storage at alternate locations
Copying existing records
Transfer of official files.
Vital records storage is discussed through providing information on key factors
which must be considered, such as choice of location, manner of storage, rotation of
records, and responsibility of custody. Information is also given on the services offered by
Federal Records Centers for vital records storage. Finally, this chapter stipulates that vital
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records programs need to be reviewed at least annually and encourages testing the program
under simulated emergency conditions.
Organizational Options
The chapter lists several guidelines LU be followed when establishing a vital records
program, including guidance on the appropriate location of certain functions (headquarters
vs. field offices).
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TTTUE:
National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Audiovisual Records. 1990
DOCUMENT OVERVIEW:
The National Archives and Records Administration (NARA) Instructional Guide
Series provides Federal agencies with detailed guidance on the management of specific
types of records. Particular emphasis is placed on the proper techniques for identifying and
handling those records that are, or may be appraised to be, permanently valuable and are
therefore intended for transfer to the National Archives. The instructional guides help
agencies create adequate and proper documentation of their activities, differentiate
permanent from temporary records, set up appropriate filing or storage systems, develop
retrieval mechanisms, and monitor the physical conditions under which records are stored
"Managing Audiovisual Records" part of the NARA Instructional Guide Series,
provides Federal agencies with derailed guidance on the management of audiovisual
records. Audiovisual records are Federal records in pictorial or aural form that include still
and motion pictures, graphic materials, sound and video recordings, and combination of
media, such as slide-tape productions. This instructional guide is specifically designed to
assist individuals responsible for the creation, maintenance and use, and disposition of
audiovisual records designated for permanent retention in the National Archives. Because
audiovisual records are most likely to be found within the Regional public affairs offices,
recruiting and training offices, historical offices and libraries, research and development
offices, and grants and projects offices, this manual is most relevant to records
management personnel in these Regional EPA offices and the Regional Records Officer if
one exits.
The handbook is organized into the following sections:
• Introduction
Locating Audiovisual Records
• Scheduling and Disposition
Potentially Permanent Records
Record Elements for Archival Purposes
Record Elements
• Management of Audiovisual Records: Some Guidelines
Filing and Identification
Storage and Preservation
Other NARA Services
Courtesy Storage of Permanent Audiovisual Records
Stock Film Depository Program
National Audiovisual Center
Disposable Audiovisual Records (Appendix A)
Series Inventory Form (Appendix B)
• Regulations (Appendix C)
Glossary (Appendix D).
EPA's Regional offices may refer to this manual for guidance on the administrative
and legal requirements associated with audiovisual records management The requirements
for receiving approval from NARS for the disposition of certain Federal records are
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explained in detail in the handbook. Sample forms and schedules are provided that will
assist the reader in taking the necessary steps with regards to the scheduling and disposition
of audiovisual records.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This handbook covers many procedural and program elements relevant to the
management of audiovisual records. In addition, the handbook provides detailed guidance
on the broad technical and legal responsibilities associated with audiovisual records
management.
File Inventory/Structure
Guidance is provided in the handbook on file inventory and file maintenance of
audiovisual records. Additionally, the handbook lists other services provided by NARA to
facilitate the agency's handling of audiovisual records. These services include courtesy
storage of permanent audiovisual records, a stock file depository program and a National
Audiovisual Center.
Life Cycle Functions
The middle sections of this handbook provide guidance on identifying,
inventorying, scheduling and either disposing of or retaining audiovisual records. These
sections outline general guidance as to the categories of audiovisual'records that are
normally of permanent value, are found in most Federal agencies and that eventually will
become part of the National Archives of the United States. It is stressed in the handbook,
however, that the descriptions are provided for general guidance and must be adopted to
reflect accurately the agency's holdings of audiovisual records. The manual describes the
following categories of audiovisual records as normally having permanent value:
Still Photography
Graphic Arts
Motion Pictures
Video Recordings
Sound Recordings
Permanent records are identified during the scheduling process. This process is
covered in detail in the handbook, with particular attention paid to the steps involved in
preparing a Standard Form (SF) 115: Request for Records Disposition Authority. The SF
115, also know as the records schedule, is the official mechanism for analyzing the value
of Government records. An agency's records management office prepares the SF 115 by
describing one or more series of records and by providing instructions for their disposition.
The SF 115 is submitted to the National Archives and Records Administration (NARA) for
review and approval.
As is the case with other types of records, most audiovisual records are not
permanent. The General Records Schedule 21, Audiovisual Records, provided in
Appendix A of the handbook, list temporary records common to most Federal offices and
give agencies the authority to dispose of such records without further clearance from
NARA. Agencies mus submit an SF 115 to NARA to obtain legal authorization of the
disposition of all other audiovisual records.
The manual is instructive with regard to specific records management program
elements. The manual provides guidance to assist in the creation, maintenance and use,
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and disposition of audiovisual records. Key steps in the records management process
addressed in the manual include: filing and identification, inventory, and scheduling and
disposition. The manual also provides guidance on the effective storage and preservation of
audiovisual records. The guidance takes into account the complex and diverse physical
attributes of audiovisual records that pose some special handling, storage and preservation
problems.
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TITLE:
National Archives and Records Administration, Office of Records Administration:
Instructional Guide Series: Managing Cartographic And Architectural Records. 1990
DOCUMENT OVERVIEW:
The National Archives and Records Administration (NARA) Instructional Guide
Series provides Federal agencies with detailed guidance on the management of specific
types of records. The instructional guides help agencies create adequate and proper
documentation of their activities, differentiate permanent from temporary records, set up
appropriate filing or storage systems, develop retrieval mechanisms, and monitor the
physical conditions under which records are stored.
This handbook offers guidance in the creation, maintenance and use, and
disposition of maps, aerial photographs, and architectural and engineering drawings. This
handbook focuses on the steps that agency records managers must take in scheduling the
disposition of maps, aenal photographs, and drawings. The handbook is organized into
the following sections:
• Introduction
• Scheduling records
• Cartographic Records
Permanent Cartographic Records
Aerial Photography
Permanent Aerial Photographic Records
Architectural and Engineering Records
Criteria for Selecting Permanent Architectural and Engineering
Records
Criteria for Identifying Significant Buildings or Objects
• Recommended Maintenance
• Disposable Records (Appendix A)
Glossary (Appendix B).
Cartographic and architectural records that are created, received or maintained by
Federal*agencies, arc Federal records, and must be managed in accordance with
administrative and legal requirements. "Managing Cartographic and Architectural Records"
is a helpful guide to the administrative and legal requirements associated with properly
administering to Agency cartographic and architectural records. The requirements for
receiving approval from NARS for the disposition of certain Federal records are explained
in detail in the handbook.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This handbook provides detailed guidance on the broad responsibilities associated
with cartographic and architectural records management. The handbook covers many
procedural aspects relevant to cartographic and architectural records management and
provides copies and interpretations of the relevant regulations and General Records
Schedules (GRS).
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File Inventory/Structure
To assist the reader in identifying, filing and inventorying records, the handbook
provides definitions of cartographic records, aerial photographs and architectural and
engineering records. In addition, the document lists, types of each of these records that are
most likely to have enduring historical value and should be scheduled for retention in the
national Archives of the United States. These descriptions are not meant to be incorporated
verbatim into an agency's schedule, but should serve as guides to the types of records that
have permanent value. The agency is instructed to adapt the descriptions to fit its own
programs.
Vital Records
Particular emphasis is placed on the proper techniques for identifying and handling
those records that are, or may be appraised to be, permanently valuable and are therefore
intended for transfer to the National Archives.
Life Cycle Functions
The manual is instructive with regard to specific records management program
elements. The manual provides guidance to assist in the creation, maintenance and use,
and disposition of cartographic and architectural records. Key steps in the records
management process addressed in the manual include: filing and identification, inventory,
storage and maintenance, and scheduling and disposition. Because maps and drawings
have diverse physical attributes, the handbook also provides some general guidelines for
properly caring for and maintaining these kinds of documents.
Sample forms and schedules are provided in the handbook that will assist the reader
in taking the necessary steps with regards to scheduling and disposition. The term
"disposition" is used to refer to what is done with records when they are no longer needed
for current business. Disposition possibilities include transferring records from one
Federal agency to another when functions are transferred, transferring them to federal
records centers, destroying temporary records, and accessing permanent records into the
National Archives of the United States. All these actions require the prior authorization of
the National Archives and Archives Administration (NARA). No records may be
destroyed without the approval of the Archivist of the United States.
The preservation and eventual transfer of permanently valuable records to the National
Archives is of special concern and emphasis. The records may exist on paper or film or as
digital data in geographic information systems (GIS), in land information systems (LIS), or
in computer aided design systems (CAD).
The handbook outlines the procedures that must be followed by the agency in
obtaining approval from the Archivist of the United States for the disposition of Federal
records. This process is known as the scheduling process. In it< an agency records
management official fills out a records schedule (Standard Form 115) in which one or more
records are described and instructions are provided for their disposition. The SF 115 is
submitted to NARA for review and approval. As a result of the scheduling process, all
records are categorized as either temporary or permanent. Temporary records are those
approved by NARA for disposal, either immediately or after a specified retention period.
Permanent records are those determined by NARA to be sufficiently valuable that they
should be preserved by the Federal Government beyond their current administrative, legal,
and fiscal uses.
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The handbook provides a sample standard Form 115 and a list of all cartographic,
aerial photographic, and architectural and engineering records that are disposable under the
authority of the General Records Schedules (GRS). The National Archives issues the GRS
to provide mandatory disposition instructions for records that are common to several or all
the agencies of the Federal Government. The appropriate GRS for all cartographic, aerial
photographic, and architectural and engineering records is found in Appendix A of this
handbook. The handbook lists as Appendix B a glossary of cartographic and architectural
records management terms. This could prove to be a helpful guide to Agency records
management officials.
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TITLE:
National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Electronic Records. 1990
DOCUMENT OVERVIEW:
The handbook "Managing Electronic Records" is addressed to the creators and
users of electronic records, Information Resources Management (IRM) officials, ADP
staff, and agency records managers. The guidance in the handbook applies to all electronic
records systems, whether on micro-, mini-, or mainframe computers, in networked or
stand-alone configurations. It focuses on electronic records that are parts of automated
information systems. The handbook is organized into the following sections:
•
Introduction
Roles and responsibilities
Disposition of electronic records: An overview
Inventorying electronic records .
Applying General Records Schedules
Scheduling records not covered by the General Records Schedules
Identifying potentially permanent electronic records
Transfer of permanent electronic records to the National Archives .
Maintenance and use of electronic records
Management Regulations (Appendix A)
Disposable Electronic Records (Appendix B).
EPA's Regional officer may refer to this manual for guidance on the administrative
and legal requirements associated electronic records management. The requirements for
receiving approval from NARA for the disposition of certain Federal records are explained
in detail in the handbook. Sample forms and schedules are provided that will assist the
reader in taking the necessary steps with regards to the scheduling and disposition of
electronic records.Special attention is devoted in the handbook to the application of
NARA's GRS. A GRS describes temporary records that are common among Federal
agencies and authorizes their disposal without further clearance from NARA. The current
GRS schedule for electronic records is provided as an appendix in the handbook.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This handbook provides detailed guidance on the broad responsibilities associated
with electronic records management. The handbook covers many procedural aspects
relevant to electronic records management and provides copies and interpretations of the
relevant regulations and General Records Schedules (GRS).
Life Cycle Functions
The crucial role of records disposition in managing electronic records is emphasized
in the handbook. Records disposition is an integral part of the total records management
program. Records disposition, records creation and records maintenance are equal parts in
the chain of records management activities. A records disposition program represents the
final phase of records management activity and contains these prime objectives:
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• The timely and systematic removal of records deemed temporary by the
creating office, the agency, and the Government for later destruction by the
agency or a records depository.
• The designation of permanent records having sufficient historical and
archival values to warrant immediate or later transfer to National Archives
and records Service (NARS) for permanent preservation.
The manual.is also instructive with regard to specific records management program
elements. Peculiar needs associated with managing electronic records addressed in the
handbook include: records inventory; identifying permanent and temporary records with the
help of the GRS for electronic records; and transferring electronic records of permanent
value to the National Archives. The handbook concludes with a brief review of some
essential maintenance guidelines for electronic records.
Organizational and Technological Options
The manual also provides guidance on organizational and technological options .
available in managing electronic records. Technological and organizational considerations
are presented throughout the manual AS the various steps associated with managing and
maintaining electronic records are detailed.
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TITLE:
National Archives and Records Administration, Micrographics: 36 Ch'K Pan 1230. July 2,
1990
DOCUMENT OVERVIEW:
This rule provides NARA standards for Federal agencies' use of micrographic
technology in the creation, use, storage, retrieval, preservation, and disposition of Federal
records. The Micrographics rule is geared primarily toward agencies' managers and staff
who establish and implement records management programs. The rule, which was
published on July 2, 1990, in the Federal Register, is divided into three main sections:
• General
Standards for microfilming records
• Standards for the storage, use, and disposition of microform records.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
All records programs which employ micrographics must comply with the standards
established in this rule. This rule applies to a variety of records management functions
including the following:
Space, Equipment and Materials
The conditions necessary for storing permanent microform records are referenced in
Subpan C.
Life Cycle Functions
Preparation of microform records and identification and indexing requirements are
also discussed in Subpan B. Standards for microform are also given in this section,
including formats for roll film, computer output microfilm, and microfiche. Additionally,
film and image requirements, such as film stock standards, processing standards, and
quality standards, for permanent, unscheduled, or temporary records,%duplicates, and user
copies records are discussed.
Subpan C provides standards for storage; specific standards are given for storing
permanent microform records are referenced. This Subpart also discusses inspection
requirements for master films of permanent record microforms and or records microfilmed
to dispose of the original record. Specifics are given on the type of sample that must be
used, the elements which must be contained in an inspection, and the reports developed
after an inspection.
Subpans B and C provide guidance on microform records disposition. Subpan B
discusses the procedures necessary to obtain authorization for the disposition or permanent
or unscheduled microform records. Subpan C offers general requirements for disposition
of microform records as well as for originals and permanent records.
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TITLE:
National Archives and Records Administration, Records Management Regulations: Final
July 2, 1990
DOCUMENT OVERVIEW:
These final rules were published in the Federal Register by the National Archives
and Records Administration (NARA) and are the text of the regulations found in 36 CFR
Parts 1220, 1222, and 1224. In the publication, NARA is revising its regulations to
provide more extensive guidance to Federal agencies about the creation and maintenance of
adequate and proper documentation of Government policies and activities. The revision
updates regulations on the creation of records currently found in Part 1222 of the Chapter •
and records maintenance regulations currently found in pan 1224 under the title of Files
Management. The revision also adds two new definitions to part 1220 and new regulations
regarding the identification of Federal records and the handling of contractor records. The
effective date of the regulations was July 1, 1990.
Revisions in the rule to Pan 1222 are extensive and focus on: establishing the
responsibility of NARA to provide guidance to Federal agencies with respect to ensuring
adequate and proper documentation of the policies and transactions of the Federal
Government, including issuing standards to improve the management of records; defining
Federal records; and outlining the responsibilities of each Federal agency in meeting the
records management requirements of 44 U.S.C. 2904, 3101, and 3102. Also, Subpan C
of Pan 1222 establishes standards for agency recordkeeping requirements.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
These rules should be read by all Regional records managers. They contain
revisions to specific, technical requirements for the creation and maintenance, the adequate
and proper documentation, and the disposition of Federal records. The rules outline the
responsibilities of each agency in ensuring compliance with applicable Government-wide
policies, procedures, and standards issued by the National Archives and Records
Administration.
Files Inventory/Structure
Pan 1220 is revised to update the definition of the term "adequate and proper
documentation". According to this revision, the term is to mean a record of the conduct of
Government business that is complete and accurate to the extent required to document the
organization, functions, policies, decisions, procedures, and essential transactions of the
agency.
Life Cycle Functions
This publication contains a revised rule entitled, "Disposition of Federal Records"
which is found in 36 CFR Pans 1220 and 1228. This rule updates, clarifies, and
reorganizes the procedures governing the disposition of Federal records. It provides
information on what documentary materials are subject to these records disposition
regulations. This revised rule distinguishes between the scheduling process and the
resulting schedules. It also establishes procedures for the temporary loan of permanent and
unscheduled Federal records.
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TITLE:
National Archives and Records Administration, Vital Records During an Emergency. 36
CFR Pan 1236, 1 July 1988
DOCUMENT OVERVIEW:
This NARA final rule, which was published in the Federal Register, provides for
the selection and protection of vital records required in the development of Federal agency
emergency preparedness programs. This rule is aimed at staff who are responsible for
implementing vital records programs. This rule is divided into the following sections:
• Background
Categories of vital records
Program considerations
Vital records storage at Federal Records Centers
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This rule provides general information on requirements for vital records programs
and updates requirements that were given previously in the 1951 Bureau of the Budget
Bulletins.
Vital Records
The rwo primary categories of vital records - emergency operating records and
rights and interests records - are defined in this rule. The rule then gives guidance on
factors which should be taken into consideration for a vital records program and provides
criteria which should be used to monitor the effectiveness of a vital records program.
This rule provides information on the vital records storage services offered at
Federal Records Centers.
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TITLE:
Federal Records Center - Seattle, Agency Records Management Evaluation. Environmental
Protection Asencv Region 10. June, 1990
DOCUMENT OVERVIEW:
The Seattle Federal Records Center (FRQ and National Archives Northwest
Region review team conducted an evaluation on the records management practices of EPA
Region 10 on June 5 through June 14. The findings of that evaluation were forwarded to
the National Archives and Records Administration (NARA) in Washington D.C. for
incorporation into the national report on EPA. This document is comprised of a cover letter
(from FRC to EPA's Region 10) and two sections of the report that was forwarded to
NARA. The two forwarded sections of the report list the significant findings of the
evaluation.
Tne contents of this report are as follows:
• Introduction
• Evaluation team
Offices Visited
Significant Findings
Findings by Office
Office of the Regional Administrator
Management Division
Hazardous Waste Division
Environmental Services Division
Air and Toxics Division
Water Division
• List of EPA Permanent Series.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
The report criticizes the headquarters records management program and the lack of
coordination between Headquarters and the Regions. The report cited a need for EPA
headquarters to improve in the areas of its records management planning, directives,
audiovisual records management and records management inspection. The heart of the
report addresses perceived problems in the Region 10 records management program.
Significant attention is devoted in this report to the records management procedures within
specific offices in Region 10. By reviewing this report. Regional records managers can
apply suggestions regarding Region 10 records management to their own programs.
File Inventory/Structure
The report observes that there is little or no standardization of filing systems within
Region 10. According to the report, each office has developed its own filing system, some
more effectively than others. Also, the report notes that there is little standardization of the
contents of case files in many offices.
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Life Cycle Functions
The report's criticisms of the Region 10 records management program components
are many and varied. They include:
• The Agency's records schedule is out of date
• There is much duplication of information in the regional office
• The provisions of the EPA records schedule are not being applied .
• Permanent records are not being systematically identified, maintained and
transferred to trie National Archives by Region 10.
Cross-Program Information Integration
"The report is critical of the overall structure of the Region 10 records management
program. It focuses its criticism on the decentralized state of records management
functions in Regions 10 whereby several branches have their own paid records managers
and are maintaining and disposing of files according to their own individual schemes. The
report calls for the formal establishment of a centralized records center that is responsible
for the collection, maintenance, disposition, and transfer to FRC of all Federal records.
Training
The report cites the need for better training in records management for both clerical
and program staff. Region 10 employees are reportedly only partially familiar with basic
records management concepts such as record versus non-record material, efficient filing
principles, records scries, and records disposition rules.
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TITLE:
Federal Records Center - Atlanta, Records Management Program Field Evaluation:
Environmental Protection Agency Region FV. April 1990
DOCUMENT OVERVIEW:
The Atlanta Federal Records Center (FRC) and National Archives-Southeast
Region review team conducted an evaluation on the records management practices of EPA
Region IV on April 12, 13, 16, 1990.
The contents of this report are. as follows:
• Contacts
Introduction
Conclusions
Recommendations
• Agency Evaluation Questionnaire
Superfund Records
Implementation of Disposition Schedules
Training
Contractors
• Permanent records
• Scientific and Research and Development Records
• Special Records.
The report emphasizes that the Headquarters records management program simply
must provide more guidance and oversight of regional programs. According to the report,
either no assistance or guidance has been forthcoming, or the regional records management
program has been reticent about carrying them out. Records schedules, manuals,
handbooks, guidelines, were either out of date or non-existent in Adanta.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
The report finds that no formal records management program for EPA's Region IV,
until the very recent past, has functioned since the Region was organized in the early
1970's. The report cites the symptoms that lead to this conclusion and offers
recommendations on how the Region IV records management program could be improved.
By reviewing this report. Regional records managers can apply suggestions regarding
Region IV records management to their own programs.
File Inventory/Structure
According to the report, the Region IV records management program could profit
form an inventory of the records in each of its units, under the direction of the Region IV
Information Services (ISS) chief. At present, nobody in Region IV knows what records
exist or where they are.
Staffing
The Region's practice of rotating a records center officer through the program
offices is supported in the report. It is argued that this has been an effective method for
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identifying and solving some of the accumulated records problems, and for educating EPA
officials about records management principles and advantages.
Life Cycle Functions
The report suggests that EPA Region FV give carerul consideration to its
practice of utilizing contractors for all if its records management program. The report
stresses that while many activities concerning record keeping are appropriate for contractors
to perform, management should review the policy now in place that develops expertise and
knowledge about EPA records-management situations in contractor personnel but not in
EPA records management officials.
Cross-Program Information Integration
The report recommends that Region FV develop a network of records officers in
each program and staff unit, to act as a liaison and communication links. It is suggested
that a formal approach to cross-program integration would be best, with records
management dunes included in a position description at a position and grade high enough to
provide an authority sufficient to carry, out the expected duties.
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TITLE:
U.S. General Services Administration, Information Resources Management Services,
Electronic Recordkeeping. July 1989
DOCUMENT OVERVIEW:
The General Services Administration (GSA) Electronic Recordkeeping handbook is
one of a series of GSA handbooks on records and information management which are
intended to help Federal agencies improve their office systems and procedures. The
purpose of this handbook is to promote effective electronic recordkeeping policies and
practices within the Federal government through the provision of guidance, not regulations.
The handbook focuses on methods and procedures which will lead to increased electronic
recordkeeping efficiency, effectiveness, and economy: The intended audience for
Electronic Recordkeeping is primarily managers in the Federal government with records
management responsibilities as well as staff who have operational responsibilities. This
handbook is divided into the following chapters:
• What is Electronic Recordkeeping?
• Establishing a Management Program
Creating Electronic Records
Using Electronic Records
Security of Electronic Records •
Coping with Emergencies
Disposition of Federal Electronic Records
Appendix - Sample Electronic Recordkeeping Management Program
Directive.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This handbook begins with general definitions and background material on
electronic records and progresses to more specific, procedural issues. Information is
provided in the following categories:
File Inventory/Structure
Steps that should be followed when inventorying electronic records are provided in
Chapter 7 of the handbook. Suggestions are given for information which should be
contained in an electronic records inventory (series or system title, inclusive dates of the
data, software and hardware used, responsible offices, how records .were created, access
restrictions, etc.) as well as potential sources of this information.
Security
Chapter 5 provides guidance on the security of electronic records based on the
premise that only properly authorized individuals should have the ability to create, review,
modify, or delete electronic records. The chapter provides further information on various
security issues, such as physical protection of equipment, media declassification and
destruction methods, electromagnetic emanations, and user identification and
authentication.
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Vital Records
Chapter 6 of the handbook offers guidance in developing contingency plans for
emergency situations with the objectives of preventing or limiting losses, minimizing the
interruption of essential services,'and designating alternatives for continuing essential
services. The handbook discusses optional backup arrangements and potential staff
responsibilities.
Public Access
Chapter 4 provides a summary of the major laws which govern public access to
electronic information and their specific requirements. These laws include FOIA, the
Privacy Act, and the Electronic Communications Privacy ACL
Staffing
Chapter 2 of the handbook provides guidance on establishing a management
program for electronic records. Tne chapter very briefly discusses general responsibilities
for both managers and stall within electronic records.
Space, Equipment and Materials
Chapter 2 lists several factors that should be considered prior to purchasing new or
upgrading current electronic recordkeeping systems. Chapter 5 provides information on
appropriate environmental conditions for equipment and other electronic materials, such as
floppy disks, hard disks, magnetic computer tape, and optical disks.
Life Cycle Functions
Chapter 3 of the handbook discusses methods and techniques for managing records
maintained in electronic media. The chapter presents two approaches to identifying
electronic records - the individual document approach and the record series approach as
well as the advantages and disadvantages of each. Standards and guidance for
recordkeeping operations, such as filenaming conventions, are also presented. The chapter
then discusses the implications of various operating procedures (i.e., saving, copying, and
erasing files) on records management, particularly record integrity. The importance of
back-ups is also discussed since electronic records generally are less stable than paper or
microform.
Chapter 3 defines two types of indexing associated with electronic records - key
field and hierarchies of words or phrases. Guidance is provided in the implementation of
these indexing schemes.
Chapters 3 and 4 discuss the credibility and the legal acceptability of electronic
records and the relationship of these two characteristics to documented procedures and to
periodic reports on the regular practice of these procedures. This discussion involves
topics such as equipment reliability, integrity of data entered, data processing and methods
used to prevent data loss, software reliability, and time and method for preparing printouts.
Disposition of electronic records is discussed in Chapter 7. Specific steps in the
disposition process, such as inventorying, reviewing existing General Records Schedules,
and developing an agency schedule, are explained, Guidance is also provided on special
handling needed for long-term preservation of electronic records.
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Organizational Options
Chapter 2 of the handbook provides guidance on establishing a management
program for electronic records. The chapter briefly discusses the place of records
management in the organizational hierarchy and the roles and responsibilities of managers
and staff within the records management program.
Technology Options
Technology options are discussed with regard to the indexing and retrieval of
electronic records in Chapter 3. Two types of computer software can perform indexing,
retrieving, and modifying procedures - Data Base Management Systems (DBMS) and Full
Text Retrieval Systems. This chapter discusses the advantages and disadvantages of each.
Combinations of the two systems are also presented.
Training
The handbook stresses the'importance of training individuals who create, edit,
store, retrieve, or dispose of electronic records in understanding basic electronic records
concepts, the technologies, and relevant procedures. Chapter 1 provides alternatives for
meeting these training needs, including self-learning centers, hotlines, and formal,
recurring classroom training.
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TITLE:
U.S. General Services Administration, Office of Information Resources Management,
Forms Management. 1985
DOCUMENT OVERVIEW:
Forms Management is one of a series of handbooks on records and information
management developed by GS A to assist Federal agencies in improving their office
systems and procedures. This publication focuses on the methods and procedures of forms
management with the objective of providing a strategy for achieving increased forms
efficiency, effectiveness, and economy. Toward this end, information is presented
according to the following sections:
The Need for Forms Management
Establishing a Forms Management Program
Operating the Program
Estimating Forms Costs
• Forms Automation.
Sample forms and organizational activity schedules are included throughout the document
to provide a blueprint for Federal agencies to follow in adapting the GSA strategy to their
needs.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
Budget Formulation/Constraints—
Resources available to the small versus large agency are considered in the
discussion of staffing and automated system configurations.
File Inventory
The handbook notes that the forms management staff is responsible for developing
methods and procedures for the storage and distribution of forms in coordination with
forms originating offices and supply facilities. The handbook also describes the role of a
"history file," as a historical record for each form.
Public Access
The handbook provides a brief synopsis of the relevance of FOIA to forms
management procedures and namely, that agencies are required to ientify restricted
information including information contained on forms, under the provisions of the ACL
Staffing
The handbook notes that the forms management staff needs managerial, analytical,
and forms design skills with capabilities in procedural analysis, forms design and
construction standards, associated equipment knowledge, typography and reproduction,
and administrative skills. The handbook also provides criteria for determining the size of
staff needed to support the program.
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Space, Equipment and Materials
The handbook discussess the options for automating the forms management
functions and describes the component equipment needed for three example system
configurations, as well as the costs, advantages, and limitations of each configuration.
Organizational Options
Overall, the handbook notes that IRM responsibilities should be carried out through
an established ERM organization with authority over agency information management
activities. It is noted that the organizational structure of a forms management program will
depend on the size, location, and forms workload of an agency. The handbook outlines
several components of the organizational structure supporting a forms management system:
personnel, functional relationships, and program functions.
Technology Options
The handbook notes that existing technology can be used to do many forms
management- related functions throughout the life cycle of the form. Automation devices
discussed in this section are categoriaed according to the cost of the system and
appropriateness to a small vs. large agency. The handbook presents three system
configurations illustrative of the type of electronic equipment currently available for use in
automated forms design, composition, and typesetting.
Training
The handbook provides a brief synopsis of the role of the forms management
program in providing training in the fundamentals of forms management and its interaction
with other agency activities. It is particularly noted that the forms management program is
the focal point for all forms-related activities in an agency.
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TITLE:
U.S. General Services Administration and National Archives and Records Service, Office
of Federal Records Centers, Records Management Handbook: Disposition of Federqj
Records. 1981
DOCUMENT OVERVIEW:
This self-described "records management handbook" provides extensive
background and guidance to all agencies of the Federal government on managing the
disposition of Federal Records. Records disposition is an integral pan of the total records
management program. Other links in the chain of records management activities, of which
records disposition is an equal pan, include records creation and records maintenance. A
records disposition program represents the final phase of records management activity.
This handbook discusses the nature of an effective records disposition program. It tells
how to set up the program, how to operate it, and how to measure its effectiveness. It
discusses how a program can be kept current in the face of constantly evolving agency
.programs and records systems and the ever-increasing volume of records created by
Federal agencies. The handbook is organized into the following sections:
The records disposition program
The schedule inventory
The schedule: records values and the appraisal process
The schedule: applying appraisal standards
The schedule: assembling, clearing, issuing
The schedule: application
Managing the records disposition program
Evaluating program effectiveness
Glossary of terms (Appendix A)
Statutes affecting records disposition (Appendix B)
Federal property management regulations affecting records disposition
(Appendix C).
It is essential that the Regional EPA offices be aware of the administrative and legal
requirements of Federal agencies in administering to and managing their records disposition
program. The requirements for receiving approval from the National Archives and Records
Service (NARS) for the disposition of certain Federal records are explained in detail in the
handbook. Sample forms and schedules are provided that will assist the reader in taking
the necessary steps with regards to scheduling and disposition.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This handbook provides extensive and detailed guidance on the broad
responsibilities associated with managing a records disposition program. Decisions made
during the disposition process with regard to the status of Federal records bear directly on
the overall effectiveness of an agency's records management program. "Disposition of
Federal Records" is laid out in an accessible and informative format that will be useful for
appropriate Regional personnel to read once thoroughly and refer to thereafter as needed.
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File Inventory/Structure
Considerable attention is given in the handbook to the procedures involved with
inventorying records. Records inventory is an important step in preparing for the schedule
and disposition of Federal records.
Staffing
This handbook provides assistance in the staffing necessary for the records
disposition function.
Life Cycle Functions
This handbook provides guidance to records management personnel on the
underlying utility of a disposition program. As indicated in the handbook, an effective
program contains these pnme objectives:
The timely and systematic removal of records deemed temporary by the
creating office, the asencv, and ihe Government for later destruction bv the
^ cr . »
agency or a records depository.
• The designation of permanent records having sufficient historical and
archival values to warrant immediate or later transfer to NARS for
permanent preservation.
After briefly explaining the nature of records disposition and its importance to the
total records management undertaking, the handbook provides detailed guidance on the
many components of the records disposition program. Disposition program components
oudined in the manual include:
The Program Directive. Issuance of an agency directive is the first step in establishing a
disposition program. Such a document, properly worded and distributed to agency
personnel, makes the program official. It signifies that the orderly retirement and
disposition of agency records is a concern. The directive is also the document through
which the agency establishes the structure of the program, defines the staffing and
organizational requirements, and outlines the role of NARS in the operation of the program
The Schedule. The schedule is the key to the records disposition program. It is the
process by which records arc identified as either temporary or permanent. This process is
comprised of a number of key steps starting with the inventory, of agency records. The
records inventory, the heart of the schedule, is a list of each type of record or series,
together with an indication of where it is located and other pertinent data. The procedures
to be followed in the inventory process are detailed in the handbook. Appraising records is
also part of the schedule process and occurs after the inventory has been completed.
During the appraisal, records and series of records are placed into "permanent" or
"disposable" categories. Detailed guidance on performing this activity is provided in the
handbook. The final element of the schedule process is the Standard Form 115 (SF 115).
The SF 115, Request for Disposition Authority, is required.for all requests to NARS for
approval of schedules. These forms must be filled out by the agency and reviewed and
approved by NARS before final action may be taken for records. SFs 115 are not required
for records covered by General Records Schedules. The handbook provides explicit
directions on filling out SFs 115 and taking action pursuant to the outcome of NARS's
review of the forms.
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Training
Regional records managers can refer to this handbook for assistance in developing
the training necessary for records disposition procedures.
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TITLE:
Reagan Administration, Executive Order 12656 - Assignment of Emergency Preparedness
Responsibilities. 18 November 1988
DOCUMENT OVERVIEW:
This Executive Order assigns emergency preparedness responsibilities to the
Federal departments and agencies. This order is prepared for managers within departments
and agencies who are responsible for implementing a vital records program, and is divided
into the following main components:
Pan 1 - Preamble
Pan 2 - General Provisions
Pans 3 - 28 - One pan for each depanment or agency.
APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:
This order provides information on emergency preparedness responsibilities of
which vital records is an important component for EPA.
Vital Records
This Order delineates the general responsibilities of various departments and
agencies for government-wide emergency preparedness. The order then discusses the
responsibilities of each Federal department and agency, including factors that need to be
considered in establishing a program, specific requirements for the program, and other
organizations, such as state and local governments, which may need to be coordinated with
in an emergency situation.
The Executive Order also defines specific responsibilities for each department and
agency. For EPA, both lead responsibilities and support responsibilities are given. An
example of a lead responsibility is the development of plans to prevent or minimize the
ecological impact of hazardous agents.
Staffing
A brief description of responsibilities and the type of position/expertise necessary to
carry out these responsibilities is given.
Training
This Executive Order discusses the need for training and education programs that
incorporate emergency preparedness and civil defense information.
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